16th Annual Tax Controversy Forum – Track II (presented by NYU School of Professional Studies)

Sharon Katz-Pearlman, Esq. | Greenberg Traurig

Sharon Katz-Pearlman focuses her practice on the representation of large multinationals, partnerships, and other taxpayers, before the IRS. She represents clients from the pre exam phase (voluntary disclosures, pre-filing agreements) through examination, appeals, and into litigation if necessary. In addition, Sharon has represented clients using the full range of IRS Alternative Dispute Resolution techniques which are available to taxpayers and advises large companies on the IRS’s Compliance Assurance Program (CAP) and other IRS specialty programs.

Sharon has deep experience with the Mutual Agreement Procedure (MAP) and the Advanced Pricing Agreement program (APA) working with Competent Authority to reach resolution on a variety of transfer pricing issues. She also consults with multinationals dealing with enforcement activity around the world, assisting them in developing practices and procedures which ensure consistency and a full understanding of the entity’s global disputes landscape. She consults frequently with clients on application to the OECD’s International Compliance Assurance Programme (ICAP) process.

Lia Colbert | Internal Revenue Service

Commissioner, Small Business/Self-Employed Division, Internal Revenue Service, Washington, DC.

Heather Maloy, Esq. | Internal Revenue Service

Chief Taxpayer Compliance Officer, Internal Revenue Service, Washington, DC.

Holly O. Paz, Esq. | Internal Revenue Service

Acting Commissioner, Large Business and International Division, Internal Revenue Service, Washington, DC.

Don Fort, CPA. | Kostelanetz LLP

John D. (Don) Fort is the Director of Investigations at Kostelanetz LLP, and the immediate past Chief of the Internal Revenue Service’s Criminal Investigation (CI) Division. Having spent nearly 30 years in law enforcement for the federal government, Don has deep expertise in financial crimes and has an extensive network of connections both within the government and in private industry.

At our firm, he assists clients facing governmental investigations involving all manner of alleged financial and economic crimes, including tax controversies or suspected tax crimes, money laundering, and Bank Secrecy Act violations. Don has an expertise in investigations involving cryptocurrency and cannabis related matters. Don also is involved in conducting internal investigations and advising clients on compliance regimes. He is available as an expert witness and litigation consultant and for voluntary or court-mandated monitorships.

Don currently provides his leadership and law enforcement expertise to the advisory boards of several fintech, anti-money laundering compliance, cryptocurrency, and cannabis compliance companies, including AML RightSource, ZenLedger, and NCS Analytics. Don also serves as Chief Business Officer with IVIX.

As Chief of IRS-CI from 2017 to 2020, Don led the sixth largest U.S. law enforcement agency, managing a budget of over $625 million and a worldwide staff of approximately 3,000, including 2,100 special agents in 21 IRS field offices and 11 foreign countries. Don’s time in law enforcement included overseeing investigations of some of the most significant financial crimes involving tax evasion, sanctions evasion, money laundering, bribery, international corruption, bank malfeasance, cyber and cryptocurrency crimes, and terrorist financing.

As both Chief and Deputy Chief of IRS-CI, he oversaw numerous high-profile matters, including the college admissions scandal known as “Varsity Blues” that ensnared several celebrities; the Paul Manafort and Michael Cohen federal tax investigations; the Michael Avenatti tax investigation; the takedown of the largest darknet child exploitation website funded by cryptocurrency; two Chinese nationals who were charged with laundering $100 million in the hack of a cryptocurrency exchange; the Swiss Bank Program in which 80 Swiss banks entered into agreements with the government and paid $1.36 billion in penalties; the Federation Internationale de Football Association (FIFA) worldwide money laundering, structuring, and tax evasion matter; the Credit Suisse guilty plea, and many more.

Don began his IRS career in 1991 as a Special Agent in Baltimore, Maryland, and later served in numerous supervisory roles before entering the Senior Executive Service in January 2011, when he was appointed to serve as a Director of Field Operations. He held that position until his appointment as Deputy Chief, IRS-CI. In 2020, Don was the recipient of the ACAMS Public-Private Partnership Award.

Don is an accomplished public speaker and serves as an expert in law enforcement, leadership, financial crimes, and enhancing public-private partnerships. Don has extensive experience in briefing high-level government officials, has testified before Congress and has provided numerous briefings to congressional staff.

Don has a Bachelor of Arts Degree in Management from Gettysburg College and is a licensed CPA in the State of Virginia.

Guy Ficco | Internal Revenue Service

Chief, Criminal Investigation Division, Internal Revenue Service, Washington, DC

Caryn Finley, Esq. | US Attorney’s Office, WDNC

Assistant US Attorney, US Attorney’s Office, Western District of North Carolina, Charlotte, NC.

Jason B. Freeman, Esq. | Freeman Law PLLC

Mr. Freeman is the founding member of Freeman Law, PLLC. He is a dual-credentialed attorney-CPA, author, law professor, and trial attorney.

Mr. Freeman has been named by Chambers & Partners as among the leading tax and litigation attorneys in the United States and to U.S. News and World Report’s Best Lawyers in America list. He is a former recipient of the American Bar Association’s “On the Rise – Top 40 Young Lawyers” in America award. Mr. Freeman was named the “Leading Tax Controversy Litigation Attorney of the Year” for the State of Texas for 2019 and 2020 by AI.

Mr. Freeman has been recognized multiple times by D Magazine, a D Magazine Partner service, as one of the Best Lawyers in Dallas, and as a Super Lawyer by Super Lawyers, a Thomson Reuters service. He has previously been recognized by Super Lawyers as a Top 100 Up-And-Coming Attorney in Texas.

Mr. Freeman currently serves as the chairman of the Texas Society of CPAs (TXCPA). He is a former chairman of the Dallas Society of CPAs (TXCPA-Dallas). Mr. Freeman also served multiple terms as the President of the North Texas chapter of the American Academy of Attorney-CPAs. He has been previously recognized as the Young CPA of the Year in the State of Texas (an award given to only one CPA in the state of Texas under 40).

Mr. Freeman serves on the law school faculty at SMU’s Dedman School of Law, where he has taught a course in the law of federal income taxation for nearly a decade, and he is a frequent public speaker across the country, presenting and educating on various legal topics.

He is also a Forbes contributor for tax and white-collar legal matters.

Mr. Freeman represents clients in litigation and disputes, with a particular focus on federal and state tax controversies, as well as white-collar and financial disputes, both civil and criminal. He handles IRS audits and other investigations and represents clients facing tax and white-collar or financial-related charges. He also advises and assists clients with tax and regulatory compliance, including domestic and international tax planning and regulatory reporting requirements, as well as cryptocurrency and Blockchain matters.

Mr. Freeman serves as trial counsel in complex business and commercial disputes, trying cases to juries and to the bench. He is experienced in civil cases involving an array of disputes, including fraud, breach of fiduciary duty, civil RICO, executor and trustee litigation, complex probate litigation, negligence, trade secrets, partnership disputes, breach of contract, and other matters.

Mr. Freeman frequently serves as an expert witness. He also represents professionals—including attorneys and CPAs—before regulatory boards and in disciplinary hearings.

Leveraging his CPA background, Mr. Freeman often represents clients in complex financial and regulatory matters that involve sophisticated forensic accounting analyses. He has handled hundreds of IRS audits and other investigations and has represented clients facing a broad array of tax and white-collar or financial-related charges, including tax evasion, bank fraud, money laundering, Bank Secrecy Act violations, securities fraud, computer intrusion and Medicare fraud, as well as clients in disputes with the Securities & Exchange Commission (SEC). He also represents clients in asset forfeiture cases.

Mr. Freeman’s litigation experience includes serving as trial counsel in a criminal tax evasion and conspiracy jury trial in the Federal District Court for the United States Virgin Islands. In addition, Mr. Freeman represents clients in appellate matters, serving as lead appellate counsel, presenting oral argument in a case before the United States Court of Appeals for the Third Circuit.

Jeremy H. Temkin, Esq. | Morvillo Abramowitz Grand Iason & Anello PC.

Jeremy H. Temkin represents individuals and corporations in white collar criminal investigations. He handles a wide variety of criminal, regulatory, and civil matters in state and federal courts and before arbitration panels. His cases have involved allegations of tax fraud and securities fraud (including claims of insider trading and accounting violations), as well as violations of the antitrust laws and the Foreign Corrupt Practices Act (“FCPA”).

Jeremy has tried high-profile tax and securities fraud cases, has conducted internal investigations for public corporations and committees of their Boards of Directors, and has represented employees in corporate internal investigations. He has counseled clients on issues relating to offshore bank accounts and the Internal Revenue Service’s Voluntary Disclosure Program, and served as Independent Examiner for numerous banks participating in the Department of Justice’s Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks. Jeremy has also represented various employees of the New York Yankees in witness interviews during investigative inquiries and he represented Muhammad Ali in civil litigation to recover stolen memorabilia.

Chambers USA: America’s Leading Lawyers in the area of Litigation: White Collar Crime & Government Investigations has described Jeremy as “a terrific litigator and one of the foremost criminal tax experts in the country,” noting that “he is well versed in international investigations, with a formidable track record in representing an impressive roster of domestic and international clients,” and that his “expert tax fraud practice is complemented by experience in criminal and regulatory proceedings related to antitrust, securities and FCPA violations.” Benchmark Litigation: The Definitive Guide to America’s Leading Litigation Firms & Attorneys has recognized Jeremy as a “Litigation Star” in the areas of White-Collar Crime/Enforcement/Investigations and General Commercial Litigation. He has also been recognized in White Collar Criminal Defense by The Legal 500 United States and has been listed in Thomson Reuters’ Super Lawyers from 2007 to the present.

From 1993 through 1999 Jeremy served as an Assistant U.S. Attorney for the Southern District of New York, where he investigated a wide variety of criminal cases – including money laundering, narcotics, tax evasion, and other fraud cases – and represented the government in numerous criminal trials and appeals. In 1998, he received the Department of Justice Director’s Award for Superior Performance as an Assistant U.S. Attorney. Jeremy joined Morvillo Abramowitz as a Partner in 1999.

Jeremy is the author of the bi-monthly “Tax Litigation” column in the New York Law Journal and a regular contributor to The Insider Blog on Forbes.com. He is also the author of the “Criminal Tax Offenses” chapter in White Collar Crime: Business and Regulatory Offenses (Law Journal Press) and a co-author of the “Responding to Subpoenas and Other Regulatory Requests” chapter in Defending Corporations and Individuals in Government Investigations (West Thomson Reuters). Jeremy has spoken on numerous issues relating to tax fraud and federal criminal practice.

In February 2022, Jeremy was elected as a Fellow of the American College of Tax Counsel. He is a member of the New York City Bar Association (Personal Income Taxation Committee, past chair; Criminal Advocacy Committee, past member; Federal Legislation Committee, past member), the American Bar Association (Litigation, Criminal Justice and Taxation Sections), the New York Council of Defense Lawyers (past director), and the Federal Bar Council. Jeremy previously served on the Board of Directors of the Legal Aid Society. In 2014, Jeremy received AJC Westchester’s Judge Learned Hand Award, the highest honor that AJC presents to outstanding leaders in the legal profession. In 2004, Jeremy received the James Fogelson Leadership Award from the UJA-Federation of New York, Lawyer’s Division.

Michael J. Desmond, Esq. | Gibson, Dunn & Crutcher LLP.

Michael Desmond is a partner in the Los Angeles and Washington, DC offices of Gibson, Dunn & Crutcher and is co-chair of the Firm’s Global Tax Controversy and Litigation Group. His practice covers a broad range of federal tax matters with a focus on tax controversy and litigation. For more than 25 years, he has represented clients before the examination divisions of the Internal Revenue Service (IRS), the IRS Independent Office of Appeals, in the United States Tax Court and in federal district courts, the Court of Federal Claims and various federal courts of appeal.

Prior to joining Gibson Dunn, Mr. Desmond served as the 48th Chief Counsel of the IRS, having been nominated by the President and confirmed by the Senate. As Chief Counsel, he was the principal legal officer for the IRS, overseeing a staff of nearly 1,500 lawyers responsible for interpreting and providing advice on all aspects of the federal tax law. During his tenure as Chief Counsel, the Office issued more than 100 sets of proposed and final regulations implementing the landmark Tax Cuts and Jobs Act and published dozens of guidance items implementing legislation enacted in response to, and providing other relief relating to, the COVID-19 pandemic. The Office was also responsible for litigating nearly 25,000 cases pending in the United States Tax Court and working with the Tax Division of the U.S. Department of Justice on cases pending in other courts around the county, including before the U.S. Supreme Court.

In private practice, Mr. Desmond has been counsel of record in numerous docketed tax matters, litigating many of them to published decision. These cover a range of federal tax issues, including application of the “property for services” rules to a contractual earn-out right; compliance with the partnership refund claim filing requirements; transferee liability; the tax treatment of partnerships holding distressed assets and debt contributed by foreign partners; interpretation of a tolling agreement in a partnership tax proceeding; fraud penalties and related adjustments; debt versus equity treatment for a partnership investment; and the valuation of customer-based intangibles. His clients have included businesses and individuals in a wide range of industries, including real estate, financial services, publishing, technology, medical services and devices, and entertainment.

Mr. Desmond previously served as Tax Legislative Counsel at the U.S. Department of Treasury from 2005 through 2008, where he was the principal legal advisor to the Treasury Secretary and Assistant Secretary (Tax Policy) on all domestic aspects of the federal tax law other than employee benefits. As Tax Legislative Counsel, he worked closely with the tax-writing committees in Congress to advance the Administration’s tax policy objectives and worked with the IRS to implement those objectives. Earlier in his career, he served as a Trial Attorney in the Tax Division of the U.S. Department of Justice, where he litigated dozens of cases pending in courts throughout the western United States. He served as a law clerk for the Honorable Ronald S.W. Lew of the U.S. District Court for the Central District of California.

Mr. Desmond is recognized as a 2023 Los Angeles “Lawyer of the Year” for Litigation and Controversy – Tax by The Best Lawyers in America®. In 2022, Chambers High Net Worth, a guide to the leading lawyers and law firms for international private wealth, recognized him in the USA: Private Client: Tax category, and he was named a Leading Lawyer by The Legal 500 – United States for US Taxes – Contentious. Prior to serving as IRS Chief Counsel, Mr. Desmond was consistently recognized by Chambers USA: America’s Leading Lawyers for Business, The Best Lawyers in America® (2010-2024) for excellence in tax and tax controversy. He served on the Council of the Tax Section of the American Bar Association and as Chair of the Section’s Standards of Tax Practice and Tax Shelters Committees and served as a Regent of the American College of Tax Counsel, where he was elected as a fellow in 2008. He served as an adjunct professor at Georgetown University Law Center from 2008 through 2015 and has been a guest lecturer at law schools around the United States.

Mr. Desmond received his J.D., magna cum laude, from the Catholic University of America, Columbus School of Law in 1994, where he served as Executive Editor of the Catholic University Law Review. He received a B.A in Political Science and History from the University of California, Santa Barbara in 1990.

Mr. Desmond is a member of the California bar, where he is certified as a specialist in tax and is also a member of the New York bar and the District of Columbia bar. He is admitted to practice before the U.S. Tax Court, the U.S. Court of Federal Claims, the U.S. District Courts for the Northern and Central Districts of California and the District of Columbia, and the U.S. Courts of Appeal for the Federal, Fourth, Seventh and Ninth Circuits.

David A. Hubbert, Esq. | US Department of Justice

Principal Deputy Assistant Attorney General, Tax Division, US Department of Justice, Washington, DC.

Nina E. Olson, Esq. | Center for Taxpayer Rights

Nina E. Olson is the Executive Director of the Center for Taxpayer Rights. From March 2001 to July 2019, Nina served as the National Taxpayer Advocate of the United States, an independent organization within the Internal Revenue Service , dedicated to assisting taxpayers resolve their problems with the IRS and making administrative and legislative recommendations to mitigate those problems systemically. She has submitted 39 annual reports to Congress, and testified before congressional committees over 60 times. Before serving as the National Taxpayer Advocate, Nina founded and directed The Community Tax Law Project, the first independent Low Income Taxpayer Clinic in the US. She also maintained a private legal practice, representing taxpayers in disputes with the IRS.

Nina has received many awards and recognitions, including the American Bar Association Section of Taxation’s Distinguished Service Award for Lifetime Service, Pro Bono Award, and Jules Ritholz Memorial Merit Award for Outstanding Dedication, Achievement, and Integrity in the Field of Civil and Criminal Tax Controversies; the Tax Foundation’s Public Sector Distinguished Service Award; and Pro Bono Awards from the Virginia State Bar, the Virginia Bar Association, and the City of Richmond Bar Association. In 2016 she was recognized by Tax Analysts as one of the Top 10 Outstanding Women in Tax (internationally).

Nina received her LLM in Taxation from Georgetown University Law Center, her JD from North Carolina Central University School of Law, and her AB (in fine arts) from Bryn Mawr College.

Frank Agostino, Esq. | Agostino & Associates, PC.

Frank Agostino is the founder and president of Agostino & Associates, P.C. Prior to entering private practice, Mr. Agostino was an attorney with the Internal Revenue Service’s District Counsel in Springfield, Illinois and Newark, New Jersey. He also served as a Special Assistant United States Attorney, where he prosecuted primarily criminal tax cases. As an adjunct professor, Mr. Agostino taught tax controversy at Seton Hall University W. Paul Stillman School of Business and Rutgers School of Law. He also served as the co-director of the Rutgers Federal Tax Law Clinic.

Mr. Agostino is a frequent speaker and author on tax controversy and litigation matters. He serves on the Advisory Board of the Journal of Tax Practice and Procedure. Mr. Agostino is actively involved with the American Bar Association and the New York County Lawyers’ Association. Mr. Agostino is also the President of Taxpayers Assistance Corp., which provides tax and legal advice to low income taxpayers in the NY/NJ area.

Jacqueline Laínez Flanagan, Esq. | Center for Taxpayer Rights

Jacqueline Laínez Flanagan joined the Center for Taxpayer Rights as Deputy Director in 2023. She previously served as the Founding Director of the Low Income Taxpayer Clinic (LITC) at the University of District of Columbia David A. Clarke School of Law, where she also taught Contracts, Federal Personal Income Taxation, and directed a Tax Policy Clinic as a pilot.

Jacq has served as a Visiting Professor of Law at American University Washington College of Law, teaching Legal Ethics, State and Local Taxation, and co-teaching in the Janet R. Spragens Federal Tax Clinic. Her other teaching appointments have included the University of Richmond, The George Washington University Law School, and the University of Memphis. Her legal practice has primarily been comprised of tax, intellectual property, and nonprofit consulting. She has represented small businesses, social enterprises, and start-ups, as well as immigrant and low wage workers.

Her legal scholarship, community service, professional presentations, and media appearances have focused on the intersection between taxation and immigration, human rights, and corporate accountability. She earned a law degree from the University of Illinois Chicago School of Law, and LL.M degrees from Georgetown University Law Center (taxation) , and The George Washington University Law School (Friedman Fellow). She is licensed to practice in Washington, D.C., and admitted to practice before the United States Tax Court.

Carlos F. Ortiz, Esq. | BakerHostetler

A seasoned trial attorney, Carlos Ortiz focuses his practice on Foreign Corrupt Practices Act (FCPA), high-risk tax controversies, offshore tax issues, anti-money laundering, e commerce fraud and healthcare fraud, as well as allegations of fraud against government agencies and financial institutions. He has extensive experience representing U.S. and foreign-based corporations and individuals in the pharmaceutical, financial services, healthcare, aerospace, energy and telecommunications industries in connection with matters before enforcement and regulatory agencies, including the U.S. Department of Justice (DOJ), the Internal Revenue Service (IRS), the Securities and Exchange Commission (SEC) and various state attorneys general. Over his career in private practice he has secured the declination of criminal charges for corporate and individual clients. On several occasions he has prevented the referral of charges for the target of criminal tax investigations.

Carlos advises corporations, their boards of directors and their committees regarding corporate governance and compliance matters. He also negotiates settlements, implements remedial measures and assists them in efficiently responding to subpoenas so as to minimize the disruptions to their normal business operations.

Before entering private practice, Carlos held posts at the Department of Justice Tax Division and at the U.S. Attorney’s Office for the District of New Jersey, where he served as Deputy and Acting Chief of the Criminal Division. Responsible for conceptualizing and leading a global financial investigation that resulted in the breakup of an international network of internet-based commercial money laundering and child pornography rings, he was honored at the White House and received an award from the National Center for Missing and Exploited Children at a congressional breakfast for his leadership role.

Carlos speaks frequently on tax enforcement and virtual currency, the FCPA, internal investigations and trial advocacy in the U.S., South America, Europe and Asia. He has been recognized by Chambers USA and both New Jersey and New York “Super Lawyers” for White-Collar Crime.

Anna C. Tavis | Brooklyn Legal Services

Staff Attorney, Brooklyn Legal Services, Brooklyn, NY.

Thomas A. Cullinan, Esq. | Chamberlain, Hrdlicka, White, Williams & Aughtry, PC.

Tom Cullinan is a Shareholder in the Firm’s Atlanta office. Tom joined the Firm from the IRS, where he served as the Counselor to the IRS Commissioner and then as the acting IRS Chief of Staff.

While at the IRS, Tom was a member of the Commissioner’s core leadership team, and he advised the IRS Commissioner on the most critical issues facing the agency, including the IRS strategic plan and budget, staffing, internal operations, enforcement of tax laws and service to taxpayers. He was particularly involved in high-level enforcement issues. Among other things, Tom either conceived or helped launch the Office of Fraud Enforcement, the Office of Promoter Investigations, and the Joint Strategic Emerging Issues Team, all of which should be key IRS enforcement tools in the coming years. Tom also helped implement various policies pertaining to cryptocurrencies and served as an invited IRS representative to several Financial Stability Oversight Council meetings regarding cryptocurrencies.

Before joining the IRS, Tom spent twenty years as a tax attorney representing taxpayers in tax controversy matters. He has represented hundreds of taxpayers, including low-income individuals in pro bono matters, high net-worth individuals, partnerships, trusts and estates, and corporations in IRS audits, administrative appeals, and litigation, on a wide variety of tax issues often with significant amounts at issue. Tom pursues every possible opportunity to resolve tax disputes and is adept at negotiating acceptable resolutions. Yet, litigation is sometimes inevitable and he has a notable track record in that regard. Notable public representations include:

American International Group, Inc. vs. United States – Tom was lead tax counsel in the insurance company’s dispute with the United States regarding its entitlement to foreign tax credits.

Klamath Strategic Investment Fund, LLC vs. United States – Tom represented the taxpayers in what is now one of the most cited cases arising out the last wave of so-called tax shelter litigation, where the courts held that the taxpayers were not subject to penalties and were entitled to deduct some of their fees and costs for entering into what the IRS called a “Son of Boss” transaction.

BASR Partnership vs. United States – Tom represented the taxpayers in the Court of Federal Claims and the Federal Circuit, where those courts disagreed with Tax Court precedent to hold that an advisor’s fraud was insufficient to hold open the statute of limitations for assessing tax and, for the first time ever, that a “TEFRA” partnership was entitled to a recovery of litigation cost from the United States pursuant to the qualified offer provisions.

Tom works in the Firm’s tax controversy practice where he draws on both his extensive background representing taxpayers and his deep knowledge of the IRS organization, operations, and procedures.

Sandra R. Brown, Esq. | Hochman, Salkin, Toscher, Perez, PC.

Sandra R. Brown joined the firm as a principal after serving most recently as the First Assistant United States Attorney for the Central District of California. Ms. Brown’s practice focuses on individuals and organizations who are involved in criminal tax investigations, including related grand jury matters, court litigation and appeals, as well as representing and advising taxpayers involved in complex and sophisticated civil tax controversies, including representing and advising taxpayers in sensitive-issue audits and administrative appeals, as well as civil litigation in federal, state and tax court.

From March 2017 to January 2018, Ms. Brown served as the Acting United States Attorney. In addition to leading the Central District of California’s United States Attorney’s Office, where she supervised approximately 270 attorneys in the largest Justice Department Office outside of Washington D.C., Ms. Brown also served as the Chief of the Tax Division for more than ten years where she supervised lawyers within the United States Attorney’s Office, the Department of Justice Tax Division and the Department of Treasury who were responsible for complex Federal civil and criminal tax matters, including related grand jury proceedings, trials and appeals.

In her more than 26 years as a federal trial lawyer, Ms. Brown obtained a vast expanse and depth of experience in complex civil and criminal tax matters, having personally handled over 2,000 cases on behalf of the United States before the United States District Court, the Ninth Circuit Court of Appeals, the United States Bankruptcy Court, the United States Bankruptcy Appellate Panel and the California Superior Court. Those cases included nationally significant civil tax cases such as two Supreme Court decisions and a multitude of published 9th Circuit decisions, as well as a broad range of equally noteworthy criminal tax cases including the first of the recent FBAR prosecutions in California, one of the largest individual tax restitution judgments fully recovered in a criminal tax case prosecuted in this nation, and the unprecedented deferred prosecution agreement, resolving a criminal probe into an international bank’s worldwide U.S. cross-border business, requiring the bank to pay $270 million in restitution and fines and to provide details about employees and more than 1,500 U.S. customers.

In addition to other honors, commendations and awards, Ms. Brown has received the Internal Revenue Service Criminal Investigation Chief’s Award and the IRS’s Mitchell Rogovin National Outstanding Support of the Office of Chief Counsel Award, respectively, the most prestigious criminal and civil awards available for presentation by the IRS to Department of Justice employees.

Ms. Brown has written, lectured and taught federal prosecutors, agents and private practitioners throughout the country on topics involving trial strategies, taxation, bankruptcy and money laundering. Based upon the breadth of her expertise and experience in litigation and management, Ms. Brown is a highly sought-after speaker before national and regional professional organizations.

Sharyn M. Fisk, Esq. | Internal Revenue Service

Sharyn Fisk, formerly a partner at Hochman, Salkin, Rettig, Toscher & Perez, PC, is a tax attorney who specializes in federal and state tax controversy matters. Ms. Fisk is a Certified Tax Law Specialist with the California State Bar. In 2017, she was appointed to the IRS Advisory Council (IRSAC). She has served as Chair of the Los Angeles County Bar Association Taxation Section Executive Committee, a board member of the Inland Empire Association of Certified Fraud Examiners, and a member of Taxation Section of both the American Bar Association and California Bar Association.

Eric Hylton | Alliantgroup

Former IRS Commissioner of the Small Business/Self Employed Division; alliantgroup National Director of Compliance.

Hylton held several prominent positions at the IRS, including serving as Deputy of the Criminal Investigation Division and as CI’s head of International Operations.

As National Director, Eric employs his years of experience at the IRS to assist alliantgroup’s clients as an ambassador for U.S. small and medium sized businesses (SMBs) and in helping others become tax compliant

Daniel Mayo, Esq. | WithumSmith+Brown, PC, Red Bank

Daniel has more than 20 years of professional tax experience as well as experience in federal, international and financial products taxation. He is experienced in mergers and acquisitions, capital markets transactions, and cross-border transactions. He is also a recognized expert in the employee retention credit and frequently represents clients in tax controversy matters before the IRS.

Daniel is a frequent author and speaker on U.S. Federal income tax topics. He is an adjunct faculty member with Georgetown University Law Center and an approved arbitrator for FINRA. Daniel is a member of the New York and New Jersey Bars, the American Bar Association, previously the chair of the Banking & Savings Institutions Tax Committee, and the New York Bar Association.

Dean Zerbe, Esq. | Zerbe, Miller, Fingeret, Frank and Jadav, LLP

Dean Zerbe was Senior Counsel and Tax Counsel for the Chairman of the Senate Finance Committee, Senator Charles E. Grassley, 2001-2008. At the direction of Chairman Grassley, Dean was the counsel responsible for the modern IRS whistleblower law – signed into law in 2006 — which established the IRS Whistleblower Office and created an award program for tax whistleblowers. Dean “wrote the law” when it comes to the IRS whistleblower office and reward program. Dean represents a select number of tax whistleblowers – including the most successful whistleblower in the history of the U.S. – Bradley Birkenfeld. Mr. Birkenfeld was awarded $104 million dollars – 26% of the $400 million in taxes paid – based on Mr. Birkenfeld blowing the whistle to the IRS about tax fraud by UBS. The award to Mr. Birkenfeld is the largest amount awarded to any individual whistleblower by the United States government. The award also represents one of the very first awards made under the IRS whistleblower law. While representing a broad range of tax whistleblowers, Dean specializes in representing whistleblowers with complex submissions. Whistleblowers have also turned to Dean to assist them in navigating the IRS and Tax Court to ensure that a prior submission is properly reviewed and considered. Dean represents whistleblowers before the Tax Court and is the author of the National Whistleblower Center’s amicus brief in the Insigna case – a landmark case for the rights of tax whistleblowers. Dean consults frequently with the Congress and the IRS about the IRS whistleblower program and has submitted extensive comments to the IRS on particular matters related to the IRS whistleblower program. In addition, Dean is widely recognized by the press as a leading authority on the IRS whistleblower law – quoted in the Wall Street Journal, Forbes, Washington Post, Tax Notes, BNA, Accounting Today and CFO Magazine. Dean has an LL.M. (Tax) from New York University as well as a J.D. with high honors from George Mason University School of Law. Prior to the Senate Finance Committee, Dean was in private practice at Lionel Sawyer & Collins in Nevada – with a focus on tax planning and tax controversy. In addition, Dean served previously in a number of positions in Congress, most notably as a staff assistant and investigator for Senator Grassley.

John W. Hinman | Whistleblower Office, Internal Revenue Service

John Hinman is the Director of the IRS Whistleblower Office. The Whistleblower Office was established by the Tax Relief and Health Care Act of 2006 and works to provide fair treatment for whistleblowers and taxpayers, and to support IRS efforts to apply tax laws with integrity and fairness. The program has offered monetary awards to whistleblowers who voluntarily expose tax law violations. Overall, the IRS has awarded whistleblowers over $1 billion based on the collection of over $6 billion in back taxes, interest, penalties, and criminal fines and sanctions.

Beverly Winstead, Esq. | Law Office of Beverly Winstead

Beverly Winstead, J.D., is a national speaker, podcaster, professor, author and principal of the law firm, Law Office of Beverly Winstead, LLC. Beverly is a personal and small business tax and legal expert who helps clients get out of tax debt and then build back and protect their wealth through wealth management strategies.

She teaches tax law at the University of Maryland, Carey School of Law, and has helped hundreds of students navigate the complexities of taxes. Taxes can be daunting for so many people but Beverly has found her calling by breaking down the tax system and sharing simple strategies that can help anyone navigate resolving a tax matter.

In her first book, Get out of Tax Debt Now, The Taxpayer Playbook to Dealing with the IRS, Beverly, a former college basketball player, uses the life skills she learned on the basketball court as a guide to helping anyone resolve their tax problems. During her tenure at Bowie State University (BSU), she won 3 conference championships. In 2014, she was inducted into the BSU Sports Hall of Fame.

Beverly can be heard weekly on a podcast: The Three Money Amigos, where she discusses a wide array of tax, legal and investment matters. In addition to her podcast, she pours a significant amount of time teaching financial literacy and entrepreneurial skills to youth. She hosts an annual financial fitness workshop for youth in underserved communities.

Mary Beth Murphy | Internal Revenue Service

Director of Collections, North Atlantic Territory, Small Business/Self-Employed Division, Internal Revenue Service, Washington, DC.

Todd Welty

Erin M. Collins, Esq. | Internal Revenue Service

Erin M. Collins is the “Voice of the Taxpayer” within the IRS and before Congress. She joined the Taxpayer Advocate Service (TAS) in March 2020 as the National Taxpayer Advocate. TAS is a safety net that advocates for resolution of individual and business taxpayer issues within the IRS and systemic change for all taxpayers while protecting Taxpayer Rights. TAS also oversees the Low Income Taxpayer Clinic (LITC) federal grant program and the Taxpayer Advocacy Panel (TAP). As part of her Annual Report to Congress, she makes administrative and legislative changes to protect taxpayer rights and works toward improving the quality of taxpayer service and tax administration.

In 2022, Erin was selected as one of the top 25 Most Powerful Women in the Accounting Profession by the American Institute of CPAs (AICPA) and CPA Practice Advisor magazine; as one of the 100 Most Influential People in Accounting by Accounting Today; and as a Changemaker: 50 Innovators Shaping Americans’ Finances by Money.com.

Erin has more than 35 years of experience in tax law, spanning 15 years in the IRS Office of Chief Counsel and 20 years at the accounting firm of KPMG LLP, from where she retired in 2019 as the Tax Managing Director in charge of its tax controversy practice for the Western region. At KPMG, Erin represented thousands of individuals, partnerships, small companies, and corporate taxpayers on technical and procedural tax matters. She represented clients in federal examinations and IRS appeals on domestic and international tax issues. She also has represented several clients before the U.S. Tax Court.

Erin was the co-author of the Practising Law Institute’s IRS Practice and Procedure Deskbook and has spoken frequently on IRS practice, procedure, controversy, and litigation matters before many professional organizations.

Before joining TAS, she represented several clients pro bono to help them resolve issues with the IRS. She was also a volunteer and board member of a non-profit organization, Step Up, whose mission was to help girls in under-resourced communities to fulfill their potential by empowering them to become confident, college-bound, career-focused, and ready to join the next generation of professional women.

Erin earned her bachelor’s degree from the University of California, Irvine, and her Juris Doctor degree from the Southwestern School of Law. She is married to Ed Robbins, Jr., and they have two children and three grandchildren.

Jennifer Breen, Esq. | Morgan Lewis & Bockius

Jennifer Breen concentrates her practice on tax controversy and planning matters, with an emphasis on audits and controversies and Internal Revenue Service (IRS) administrative proceedings. Jennifer routinely handles matters involving US federal income tax, foreign tax, state and local corporate and business tax, and sales and use tax. She has experience representing major corporations, partnerships, S corporations, and individuals in resolving domestic and international compliance and controversy issues before the IRS.

Diana L. Erbsen, Esq. | DLA Piper

Diana Erbsen has more than two decades of experience in tax controversy, representing clients in all aspects of sophisticated, challenging, and often high stakes tax disputes. In 2014, Diana was appointed to the position of Deputy Assistant Attorney General for Appellate and Review for the Tax Division of the US Department of Justice by President Obama. Following the end of the administration on January 20, 2017, Diana returned to DLA Piper as a partner.

In her capacity as a Presidential appointee to the DOJ’s Tax Division, Diana oversaw its largest section, the Appellate Section (which is responsible for all appellate litigation, including to the Supreme Court), the Office of Review (which is responsible for civil settlements), and the Financial Litigation Unit (a unit tasked with collecting judgments secured by the Trial Sections of the Tax Division). Additionally, she was actively involved in the management and operations of the Civil and Criminal sections of the Tax Division and served in an ex officio capacity on the Bankruptcy Rules Advisory Committee. In January 2017, Diana was recognized by IRS Chief Counsel William Wilkins with the Chief Counsel Award for her leadership and oversight of the Appellate Section.

Since returning to DLA, Diana has resumed representing public and privately held corporations, as well as partnerships, estates and individuals, in all aspects of tax disputes. She concentrates her practice on federal, state and local tax controversies, including criminal tax matters. Informed by her experience at the DOJ and her historical perspective, she regularly counsels clients on issues relating to judicial deference to IRS guidance, including regulations, as well as on the appeal process and the intersection of criminal and civil tax enforcement.

In 2020, Diana served as Chair of the IRS Advisory Council (IRSAC), which advises the IRS Commissioner on tax administration issues. In 2019, she served as Chair of IRSAC’s Large Business & International Subgroup, after having been selected in 2018 to serve a three year term on IRSAC. Diana’s IRSAC service, along with her role in the leadership of the American Bar Association Tax Section, facilitates her ability to provide up to the minute guidance to clients and to help improve tax administration for the benefit of taxpayers and the IRS.

Diana has also been recognized by the American College of Tax Counsel as a Fellow.

The Hon. Elizabeth A. Copeland | United States Tax Court

Judge, United States Tax Court, Washington, DC

Marjorie A. Rollinson, Esq. | Internal Revenue Service

Chief Counsel, Office of Chief Counsel, Internal Revenue Service, Washington, DC.

Heather Fincher, Esq. | Kostelanetz

Heather Fincher advises multinational businesses and high-net-worth individuals on US federal income tax matters, with a particular focus on international tax planning and controversies. She counsels both US- and foreign-owned businesses and individuals regarding the US tax consequences of cross-border investments, cryptocurrency issues, mergers and acquisitions, joint ventures and restructurings. Heather also regularly advises clients on special issues arising in international tax controversies.

Before joining Kostelanetz LLP, Heather worked as a tax attorney at the Washington, DC office of BakerHostetler, served a Fortune 50 company through her own firm and launched an international tax education business. During law school, she gained experience and insight into the inner workings of Treasury, the Tax Court and in-house legal practices: she served as a tax law clerk at Berkshire Hathaway, interned for Chief Judge Michael B. Thornton and Senior Judge Albert G. Lauber of the United States Tax Court, and interned in the Office of the International Tax Counsel at the US Department of the Treasury in Washington, DC.

Heather earned an LLM in Taxation, with distinction, and a Certificate in International Taxation from Georgetown Law. She earned her JD, with high honors, from GW Law, where she was a George Washington Scholar. Additionally, Heather earned a Master’s in Taxation, with high distinction, from Bentley University. Prior to her academic accomplishments in law and taxation, Heather earned her Bachelor’s degree and a Master’s degree in Intercultural Studies, with a Certificate in Leadership, from Wheaton College.

Heather is involved in a number of professional associations and is an active champion for professional women. She co-founded the American Bar Association’s Women in Tax Forum, and in 2023, Heather launched the Powerful Professional Women podcast.

David Farhat, Esq. | Skadden, Arps, Slate, Meagher & Flom LLP.

David Farhat focuses on all phases of international tax planning and dispute resolution, having advised some of the largest companies in North America, Europe and Asia on their most complex multijurisdictional tax issues.

Mr. Farhat has extensive experience in resolving contentious and complex transfer pricing disputes, and during his career he has built significant relationships with tax authorities both in the U.S. and internationally.

Mr. Farhat worked at the IRS for nearly a decade and handled a variety of issues involving the Advance Pricing and Mutual Agreement (APMA) program. As an APMA team leader, he developed and negotiated bilateral and multilateral advance pricing agreements and mutual agreement procedures with several U.S. treaty partners, including the U.K., France, Japan, Canada and Switzerland. From his tenure at the IRS, Mr. Farhat also has extensive experience engaging with the agency’s Large Business & International Exam and Chief Counsel divisions.

Prior to joining Skadden, Mr. Farhat was a partner at a major global accounting firm. In addition to resolving transfer pricing disputes in various jurisdictions outside the U.S., he provided international tax advice in treaty processes to resolve double taxation and tax jurisdiction disputes.

In 2022, Mr. Farhat was recognized as a finalist by The American Lawyer for its Best Mentor: Law Firm award. He is the co-host of Skadden’s “GILTI Conscience” podcast, which features discussions on pressing transfer pricing issues, international tax reform efforts and tax administration trends. This ongoing podcast series is available on all major podcast platforms.

Joshua Odintz, Esq. | Holland & Knight LLP

Joshua D. Odintz is a tax attorney in Holland & Knight’s Washington, D.C., office. Mr. Odintz focuses on tax policy, tax controversy and tax planning matters.

Mr. Odintz represents clients before the U.S. Department of the Treasury, Internal Revenue Service (IRS), U.S. Congress and the Organisation for Economic Co-operation and Development (OECD). He assists clients in seeking legislative and regulatory changes to tax laws, as well as monitoring key legislative and regulatory developments. Significant issues include OECD Pillars One and Two, global intangible low-taxed income (GILTI), base erosion and anti-abuse tax (BEAT), foreign-derived intangible income (FDII), foreign tax credits, debt versus equity, the deductibility of research expenses, interest limitations, mark-to-market on financial products, Foreign Account Tax Compliance Act (FATCA), Common Reporting Standard, Build Back Better Act and Inflation Reduction Act.

Further, Mr. Odintz represents clients under investigation by Congress regarding tax issues.

Mr. Odintz also advises clients on domestic and international tax controversy matters at all phases, from audit and administrative appeals through litigation. He has experience handling cases involving methods of accounting, transfer pricing, Section 199, research credit, tax accounting, attorney-client privilege and work product, among others.

Mr. Odintz works with multinational businesses to structure their inbound and outbound investments, including in light of the significant changes under OECD/G20 Pillar Two.
Mr. Odintz is active in Holland & Knight’s pro bono program and serves as co-chair for the firm’s Washington, D.C., office.

In addition to his legal practice, Mr. Odintz is a frequent speaker at the International Fiscal Association (IFA), Tax Executives Institute (TEI), American Bar Association (ABA), University of Chicago Tax Conference, International Bar Association (IBA) and District of Columbia Bar.

Mr. Odintz spends his free time writing tax articles for various publications. He is a frequent contributor to the Knight Watch column in TAXES magazine, and his most (in)famous article, “The TCJA is Not for Losers,” appeared in Bloomberg’s Tax Management International Journal.

Prior to joining Holland & Knight, Mr. Odintz was a tax attorney at a multinational law firm’s Washington, D.C., office, where he was on the management committee of the firm’s North America tax practice.

In addition, Mr. Odintz has held high-level government positions with the U.S. Department of the Treasury and the Senate Committee on Finance. He previously served as a senior advisor for tax reform to the assistant secretary at the Treasury Department, where he advised senior treasury officials on tax reform options and issues. Mr. Odintz also served as the chief tax counsel to President Barack Obama’s National Commission on Fiscal Responsibility and Reform and was instrumental in formulating the tax proposals in the commission’s report. Additionally, Mr. Odintz served as the acting tax legislative counsel at the Treasury Department.

Christopher Slade | Aird & Berlis LLP

Chris is a skilled advocate with extensive experience advising on domestic and international tax controversy and litigation matters. He has successfully represented a wide range of clients, including multinational corporations, financial institutions, pension funds and ultra high net worth individuals, and he routinely acts on high value and complex cases. Chris’ strategic approach allows him to position his clients for effective negotiation with the tax authorities, with the objective of obtaining favourable results efficiently and avoiding litigation when possible. He has an exceptional track record, having successfully resolved most of his cases by consent judgment or at the administrative appeals level.

Chris is a member of the firm’s Tax Group and Tax Controversy/Tax Litigation Group. In addition to handling tax litigation matters, his practice includes advising clients throughout the audit process, remediation of tax compliance errors and making disclosures under the Voluntary Disclosures Program, obtaining interest and penalty relief and other discretionary remedies, and challenging collection action (and other administrative action) taken by the tax authorities, particularly in the cross-border context. He also collaborates with other members of the Tax Group to assist clients with transactional and tax advisory matters.

Chris is recognized by Chambers and Partners as a leading lawyer in the area of Tax: Litigation and has been recognized since 2019 in International Tax Review’s World Tax Guide for his expertise in Tax Controversy. He has published articles on a variety of tax issues in professional legal journals and is a co-author of the Chambers Tax Controversy 2023 Global Practice Guide (Canada Chapter). Chris has also presented at various conferences and other events for tax executives and tax practitioners in Canada and internationally.

Early in his legal career, Chris completed a judicial clerkship at the Tax Court of Canada. Prior to joining Aird & Berlis, Chris was a senior partner at a national law firm affiliated with one of the Big 4 accounting firms, where he co-led the affiliated firm’s tax litigation practice in Toronto.

Andrew Weiner, Esq. | Kostelanetz

Andy is a contributing author to Tax Notes Federal and the forthcoming edition of the ABA Tax Section’s Effectively Representing Your Client Before the IRS, among other publications, and a frequent speaker including for the ABA Tax Section, the Philadelphia Bar Association Tax Section, the LITC Program Office, and the Center for Taxpayer Rights.

Andy started his legal career in clerking for Chief Justice Deborah T. Poritz of the New Jersey Supreme Court and Judge Stanley Marcus of the U.S. Court of Appeals for the Eleventh Circuit. He was a litigation associate in the D.C. office of O’Melveny & Myers for three years before joining the Department of Justice. He earned an LL.M. in Taxation from Georgetown Law Center, a J.D. cum laude from the University of Pennsylvania Law School, and a B.A. magna cum laude from Bowdoin College.

David W. Foster, Esq. | Kirkland & Ellis

David Foster is a partner in the Tax Practice Group in the Washington, D.C., office of Kirkland & Ellis LLP. David advises a broad range of clients, including large corporations, private equity firms and hedge funds, partnerships, estates, exempt organizations and individuals, many of whom are subject to the IRS’ Global High Wealth initiative. His practice covers a diverse range of tax issues, including international tax and transfer pricing, TEFRA and BBA partnership audit and litigation procedures, taxation of financial products, estate and gift taxes, deferred compensation, voluntary disclosures and criminal tax.

A former Supreme Court clerk, David has prepared briefs and argued before many of the federal courts of appeals. Prior to joining Kirkland, he obtained a rare taxpayer victory striking down a Treasury Regulation in Hewitt v. Commissioner, 21 F.4th 1336 (11th Cir. 2021). He also represented five former IRS commissioners in a D.C. Circuit amicus brief in Loving v. IRS in support of licensing standards for tax return preparers, as well as the American College of Tax Counsel in amicus briefs in the Tax Court and the Supreme Court.

Katherine Jordan, Esq. | GBX Group

As Director of Tax Controversy at GBX Group, Katherine is responsible for managing the firm’s federal tax audits, appeals, and litigation. Katherine is well-versed in tax controversy matters and works to ensure that GBX’s tax transactions are fully compliant with all federal tax laws.

Prior to joining GBX, Katherine practiced as a Tax Controversy and Litigation Associate at Chamberlain, Hrdlicka, White, Williams & Aughtry, where she represented clients in audits and administrative appeals before the Internal Revenue Service and in litigation before the United States Tax Court. Katherine also previously served as a law clerk to the Honorable Joseph W. Nega of the U.S. Tax Court, where she drafted opinions, orders, and decisions and conducted legal research on a wide variety of tax matters.

Katherine co-authored the Tax Notes article “Eroding Conservation, Preserving Abuse – A Flawed IRS Strategy”, which Tax Notes recognized as one of the 10 best federal tax articles of 2020.

Katherine earned her Bachelor of Arts in Political Science from Duke University and her Juris Doctor from

The University of Virginia School of Law where she concentrated in tax law.

Michelle Abroms Levin, Esq. | Dentons

Michelle Abroms Levin is a shareholder in Dentons Sirote’s Huntsville, Alabama office, where she is a member of the Tax practice group and manages the Huntsville office. She represents clients during all phases of federal income tax controversies, including IRS audit, administrative appeals, and court proceedings in the U.S. Tax Court, U.S. Court of Federal Claims, federal district court and the Courts of Appeals. Michelle has secured major victories for her clients in the Eleventh Circuit, Fifth Circuit, Tax Court, elevating important Administrative Procedure Act issues in the tax controversy context. Her experience includes a wide range of complex tax issues. Michelle also counsels clients in tax and business planning. She works with clients to structure transactions in a manner that maximizes tax benefits, reduces risk, and complies with tax law at local, state, and federal levels.

Prior to joining Dentons Sirote (formerly Sirote & Permutt, PC), Michelle worked as a trial attorney at the Tax Division of the Department of Justice, where she represented the United States in federal district court.

Emily P. Hughes, PC, Esq. | Kirkland & Ellis

Emily P. Hughes is a litigation partner in the Washington, D.C., office of Kirkland & Ellis LLP. Her practice focuses on counseling and defense of companies, partnerships, individuals, and non-profits in civil and criminal matters, particularly where tax or other complex financial matters are involved. Emily is a problem solver who is uniquely attuned to the needs and issues confronting closely-held enterprises, including private equity sponsors and their founders and shareholders in private companies.

Emily’s government and regulatory investigation experience includes representations before the IRS and DOJ, ranging from civil examinations to grand jury and trial proceedings. She has led multidisciplinary teams in complex and sensitive internal investigations. Emily is experienced in crisis management and has guided CEOs, senior executives, and Board of Directors through crisis preparedness, mitigation, and response in the context of both internal and governmental investigations.

Emily litigates on behalf of and defends corporations, partnerships, and individuals in matters involving tax reporting and treatment, international tax and information reporting (including Section 965 transition tax disputes), voluntary disclosures and closing agreements, securities and financial fraud, fiduciary duty claims, and tax disputes arising in the bankruptcy context.

She also has litigated and counseled on a range of disputes in closely-held business contexts, including the defense of founders’ business interests in founder break-ups and marital dissolution and partner business disputes.

Emily is a fellow of the American College of Tax Counsel and previously served as vice-chair and chair of the D.C. Bar’s Tax Audits and Litigation Committee.

Niles A. Elber, Esq. | Caplin & Drysdale

Niles A. Elber, a Member in Caplin & Drysdale’s Washington, D.C., office, has more than 20 years of experience representing clients in civil and criminal tax controversies. His practice is broad, ranging on the civil side from IRS examinations, Appeals matters, collections and proceedings in federal court while on the criminal side handling both administrative and grand jury tax investigations. With considerable experience in offshore compliance matters for U.S. taxpayers, Mr. Elber has assisted hundreds of clients with their voluntary disclosures and income tax and FBAR penalty exams related to unreported foreign bank accounts.

S. Starling Marshall, Esq. | Crowell & Moring

When clients face complex commercial and tax disputes, they rely on S. Starling Marshall as their advocate and counselor. Starling is a trial lawyer with over 15 years of experience who has successfully represented clients before federal and state courts, arbitration panels, and administrative tribunals. Drawing on her years of government service and private practice, she guides clients toward business-minded solutions throughout all phases of an investigation or litigation.

Starling is a partner in the Litigation and Tax groups in the firm’s New York office. In addition to representing clients in all stages of litigation, she guides clients through complex IRS audits and administrative appeals, provides tax-related advice, conducts internal investigations, and represents individuals and corporate entities in criminal tax matters.

Prior to entering private practice, Starling served as a trial attorney in the U.S. Department of Justice’s Tax Division. During her time at the DOJ, she litigated cases before federal district courts and the Court of Federal Claims. Starling focused on complex tax shelter matters involving partnerships and penalty issues and cases in the energy industry, including cases involving Section 1603 grants for renewable energy projects and nuclear decommissioning liabilities. For her service, the DOJ awarded her the Outstanding Attorney Award (2015) and the Special Commendation for Outstanding Contribution (2013). From 2010 to 2014, Starling worked with the DOJ’s Office of Legal Policy to vet candidates for the federal judiciary.

From 2008 to 2009, Starling served as a law clerk to the Hon. Victor Marrero of the U.S. District Court for the Southern District of New York.

Her pro bono work includes serving as lead counsel with the American Civil Liberties Union’s Immigrant Rights Project and with ACLU-Utah in a Bivens action against U.S. marshals who raided a family’s home on two successive days. Starling received the New York County Lawyers Association Conspicuous Service Award for authoring a chapter in “Commercial Litigation in New York State Courts,” fifth edition, a joint venture of Thomson Reuters and the New York County Lawyers Association.

Fran Obeid, Esq. | MFO LAW, PC.

Fran Obeid is the founder of MFO LAW, P.C. She represents individual and corporate clients in civil and criminal matters involving the Internal Revenue Service, state and city tax agencies, the tax division of the Department of Justice, the United States Attorney’s Office, the District Attorney’s Office, the New York State Attorney General as well as other government agencies.

Ms. Obeid has represented numerous clients residing throughout the world with undisclosed offshore accounts advising on disclosure and compliance alternatives and guiding them through the process. She defends clients in federal and state audits, including residency and sales tax audits and advises on how to prevent such audits.

Ms. Obeid represents non-filers; alleged responsible persons and has successfully obtained significant abatements of penalties. Ms. Obeid has represented individual witnesses and accounting firms before the U.S. Attorney’s Office, the Criminal Investigation unit of the IRS as well as before the New York State Attorney General. She regularly interacts with revenue officers and agents, IRS Appeals officers, IRS Counsel, criminal investigators, Assistant United States Attorneys and Assistant Attorney Generals, taking the right approach to best meet the client’s needs, whether it be defending a civil examination, criminal investigation or indictment, or subpoena demand.

Michel R. Stein | Hochman Salkin Toscher Perez P.C.
MICHEL R. STEIN is a principal at Hochman Salkin Toscher Perez, specializing in tax controversies, as well as tax planning for individuals, businesses and corporations. For more than 25 years, he has represented individuals with sensitive issue civil tax examinations where substantial penalty issues may arise, and extensively advised individuals on foreign and domestic voluntary disclosures regarding foreign account and asset compliance matters.

Mr. Stein is well respected for his expertise and judgment in handling matters arising from the U.S. Government’s ongoing enforcement efforts regarding undeclared interests in foreign financial accounts and assets, including various methods of participating in a timely voluntary disclosure to minimize potential exposure to civil tax penalties and avoiding a criminal tax prosecution referral. He has assisted hundreds of individuals who have come into compliance with their foreign reporting requirements through the OVDP, Streamline or otherwise.

Throughout his career, Mr. Stein has represented thousands of individual, business and corporate taxpayers involved in civil examinations and administrative appeals, tax collection matters as well as with possible assertions of fraudulent conduct and in defending criminal tax investigations and prosecutions at every administrative level within the IRS. He has litigated tax cases in the U.S. Tax Court, the U.S. District Court, and various U.S. Circuit Courts of Appeal. He continues to provide tax advice to taxpayer’s and their advisors around the world.

Mr. Stein is a frequent lecturer at national and regional conferences on topics including tax compliance sensitive issues, IRS examinations, State and Federal worker classification issues, etc. Mr. Stein received his LL.M. in Taxation from the NYU School of Law and graduated from the University of California, Hastings College of the Law. He gained further expertise as Attorney-Adviser to the Honorable Judge Larry L. Nameroff of the U.S. Tax Court. He is a Certified Specialist in Taxation Law by the State Bar of California, Board of Legal Specialization.

Byung Hyuk Min, Esq. | Agostino & Associates

Mr. Min is an associate attorney with Agostino & Associates P.C. and is admitted to practice in New Jersey and the US Tax Court.

He graduated at the top of his class in Tax Law from Rutgers Law School and is an active member of the American Bar Association (ABA) Tax Section.

Daniel N. Price, Esq. | Law Offices of Daniel N. Price

Dan’s legal practice focuses on tax and Title 31 (Bank Secrecy Act) controversy matters with the IRS and tax matters before certain state tax authorities. For over nineteen years, Dan served as an attorney for the Office of Chief Counsel of the Internal Revenue Service. As a former trial attorney and manager (supervisory trial attorney) with the Office of Chief Counsel and as a Special Assistant United States Attorney, Dan has had unique experience with tax controversy and tax administration.

Dan’s prior government service included extensive work in the arena of international enforcement and included assisting the IRS in completely revising the Voluntary Disclosure Practice. Dan also worked with the Offshore Voluntary Disclosure Programs, the Streamlined Filing Compliance Procedures, foreign bank account reporting, Bank Secrecy Act investigations, various LB&I compliance campaigns, expatriation issues, international collection of taxes, and much more. Dan served as a Chief Counsel “FBAR Coordinator” reviewing willful FBAR penalty cases proposed by IRS revenue agents. Dan was also part of the Chief Counsel team who met quarterly with the Department of Justice Tax Division on FBAR cases and annually on significant international enforcement matters.

In July of 2014, the Chief Counsel appointed Dan the Managing Counsel of the Austin, Texas, post of duty. Dan also provided countless training sessions to IRS and Chief Counsel personnel across the United States and Puerto Rico and taught as an instructor in Chief Counsel schools such as Discovery School and Advanced Trial Advocacy School. Dan also served as a spokesperson for the IRS, giving presentations in the United States, Mexico, and Canada on international compliance issues. Dan had a truly rare, well-rounded career with the Office of Chief Counsel. He tried many cases as a trial attorney, managed paralegals and attorneys, and departed the government at the end of 2021 as a valued member of the teams overseeing the Voluntary Disclosure Practice, the Streamlined Filing Compliance Procedures, the Relief Procedures for Certain Former Citizens, and other projects with national and international scope.

Beyond Dan’s normal tax practice, he has an active pro bono practice in both tax, immigration asylum, and other matters. Dan spent the year 2022 volunteering his legal services as in-house counsel with a nonprofit. In the tax realm, Dan has represented low-income taxpayers pro bono in Tax Court proceedings and in administrative proceedings including abatement requests of unjustified international information return penalties. Dan taught in a tax webinar on tax compliance issues for refugees; the webinar was tailored to help volunteer tax return preparers assisting asylum seekers. Dan also volunteers as a member of the Form 3520 Task Force of the American Institute of Certified Public Accountants (AICPA).

In immigration asylum matters, Dan has handled defensive asylum claims in Immigration Court removal proceedings and affirmative asylum claims before the U.S.C.I.S. The San Diego Union-Tribune published articles written by the esteemed immigration reporter Kate Morrisey on January 1, 2023, and January 14, 2023, featuring one of Dan’s asylum cases in Immigration Court in San Diego. Ms. Morrisey’s January 14, 2023, article quoted Immigration Court Judge Scott Simpson regarding Dan’s work: “Through the assistance of your attorney, this has been the most well-documented asylum case I have ever seen.”

Dan occasionally blogs for the tax blog Procedurally Taxing and writes tax-related posts on LinkedIn. Here’s a link to the Nov./Dec. 2022 issue of the EA Journal which featured Dan’s cover article When Your Client Says, “I’ll Fake a Receipt.” Dan has also provided input to the government in response to various requests for public comments. Here’s a link to Dan’s letter in response to the IRS’ December 2022 request for public comments on Forms 3520 and 3520-A.

Lawrence A. Sannicandro, Esq. | McCarter & English, LLP.

Larry has favorably resolved hundreds of federal and state tax controversies, many of which involved sophisticated and complex tax issues that established legal precedent.

Lawrence (Larry) Sannicandro focuses his practice on federal and state tax controversies, including representation in audits, administrative appeals, collection matters, summons proceedings, criminal tax investigations and prosecutions, and litigation in the United States Tax Court, federal district and appellate courts, and state tax tribunals. He has extensive experience providing tax-related advice with respect to original tax return reporting positions on a broad range of substantive tax issues, amending tax returns, filing and litigating claims for refund, challenging civil tax penalties, reporting foreign assets and income, and making voluntary disclosures.

Drawing on his unique experience as a former estate and gift tax attorney for the IRS, Larry is particularly well-versed in estate and gift tax planning techniques, as well as the valuation of closely held businesses, and defending those techniques and valuations in disputes with tax authorities. He also counsels clients on all facets of estate, business, and tax planning, including the formation, operation, transfer, and termination of business entities.

Larry is a member of the Internal Revenue Service Advisory Council (IRSAC) and a fellow of the American College of Tax Counsel. He serves the American Bar Association (ABA) Section of Taxation as a vice chair of the Court Procedure and Practice Committee as well as a member of the Appointments to the Tax Court Committee. He was also a past Chair of the ABA Section of Taxation’s Committee on Tax Collection, Bankruptcy and Workouts. On behalf of the Tax Section, he has drafted comments to Congress, the IRS, the Treasury Department, and the United States Tax Court on a wide range of tax issues, such as reforming the procedures for auditing and litigating against partnerships and the need to adopt a voluntary disclosure program for unreported cryptocurrency transactions.

Larry also teaches a course in tax practice and procedure as an adjunct professor at Fairleigh Dickinson University, and he has taught classes on corporate tax, partnership tax, legal ethics, and negotiations as an adjunct professor at Pace University and a lecturer at Georgetown University Law Center and Rutgers Law School.

Larry is a dedicated pro bono advocate who uses his tax expertise to give back to the community. He works with the After Innocence organization to provide tax-related advice to wrongfully convicted individuals. For his work in co-designing and co-implementing an entirely new form of low-income taxpayer assistance, the ABA Section of Taxation awarded Larry the 2020 Janet Spragens Pro Bono award, the Section of Taxation’s highest award for pro bono. Larry also regularly appears on behalf of taxpayers as part of the New York County Lawyers Association’s U.S. Tax Court Calendar Call Program. The New York County Lawyers Association awarded Larry its Pro Bono Award in 2015. Larry is a member of the Supreme Court of New Jersey District VA Ethics Committee, and he proudly serves as a trustee of Integrity House, one of the largest non-profit providers of substance use disorder treatment in New Jersey.

Prior to entering private practice, Larry served as a law clerk for the United States Tax Court. He earned his LLM in Taxation from Georgetown University Law Center, his JD from the University of Florida Levin College of Law, and his MBA in Finance from Binghamton University.

Larry is a frequent author on tax practice and procedure, having published articles in the Journal of Tax Practice and Procedure, Tax Notes (including Tax Notes State), TAXES – The Tax Magazine®, and The New Jersey Law Journal, among other regarded periodicals. He is the author of the BNA Tax Management Portfolio on Innocent Spouse and a co-author of Qualified Appraiser, Qualified Appraisal: Practice, Procedure, Legal Analysis, and Theory (John Wiley & Sons, Inc. 2017), and Tax Practitioner’s Guide to Identity Theft (CCH, Inc. 1st ed. 2015; 2d ed. 2016). He is also a contributing author to the Effectively Representing Your Client Before the IRS (Chapter 10 of the ABA Section of Taxation’s book).

Zhanna A. Ziering, Esq. | Moore Tax Law Group

Zhanna A. Ziering, a tax controversy and litigation attorney, is a Member in the Firm’s New York office. Ms. Ziering’s practice focuses on representing individual and entity clients in civil and criminal tax disputes with federal and state governments as well as in regulatory proceedings. She defends both individual and entity taxpayers before the U.S. Tax Court, federal and state courts, and administrative agencies, including the Internal Revenue Service, the Department of Justice, and other federal and state government regulators.

Ms. Ziering advises taxpayers in connection with various tax issue, including those arising in connection with domestic and offshore income and assets, cryptocurrency, and U.S. tax and regulatory reporting requirements. She approaches each of her client engagements with empathy and kindness and develops a strategy for dispute resolution by taking the client’s views, needs, and resources into consideration. When faced with alternatives for dispute resolution, Ms. Ziering discusses the various available options, and the benefits and drawbacks of each such option, with the clients and works together with them to develop the approach tailored to that particular client and situation.

Ms. Ziering strives to resolve every tax dispute that her clients are facing amicably and efficiently while zealously advocating on her clients’ behalf. Her significant experience in representing clients in various stages of a tax dispute allows her to aptly navigate the procedural hurdles and achieve best results possible under the circumstances for each client.

A well-regarded member of the legal community, Ms. Ziering is actively engaged in American Bar Association, Section of Taxation. She currently serves as the Vice Chair of Court Practice and Procedure Committee. Ms. Ziering is also a sought-after speaker and writer on various topics relating to tax controversy and litigation. She is a co-author of the Bloomberg BNA’s Tax Management Portfolio, Report of Foreign Bank and Financial Accounts.

An avid supporter of the arts, Ms. Ziering had offered pro bono tax representation to artists from a diverse range of industries, such as film, music, and fashion. She also provided counsel to low-income taxpayers with a broad range of tax issues through Duke University School of Law’s Low-Income Taxpayer Clinic and New York University School of Law’s Tax Clinic.

Ms. Ziering lives in New Jersey with her husband, two rambunctious boys, and a Chocolate Labrador, named Mr. Chance Broadway. Ms. Ziering is a native Russian speaker and insists on reading all the great Russian literature in its original language.

Miri Forster, Esq. | Eisner Advisory Group

Miri Forster is a Partner and National Leader of the Tax Controversy & Dispute Resolution practice group, specializing in providing tax dispute resolution services to public and private corporations, partnerships and high net worth individuals on a wide range of technical and procedural issues. She has over 20 years of IRS practice, procedure, and tax controversy experience.

Miri represents businesses and individuals before the IRS Examination and Appeals Divisions on complex domestic and international tax issues. She also obtains private letter rulings from the IRS National Office, including 9100 relief requests for missed elections. Miri assists clients with voluntary disclosures of inadvertent income, international information return, withholding, and payroll tax compliance errors, obtains penalty abatements and refunds, resolves IRS account issues, and advises on a broad range of IRS practice, procedure and dispute resolution matters.

Prior to joining the firm, Miri was a Tax Controversy Principal at a Big 4 firm. Miri also previously served as an Attorney-Advisor at the United States Tax Court in Washington, D.C., and is an attorney licensed in the states of New York and New Jersey as well as Washington, D.C.

Miri is a frequent speaker on IRS enforcement trends, the centralized partnership audit regime and its impact on pass-through entities and investors, voluntary disclosures of inadvertent tax compliance matters and related penalties, and other IRS practice, procedure and dispute resolution topics.

Miri was named a 2022 honoree of the Executive Women of New Jersey’s Policy Makers. She also serves as Co-chair of Women of EisnerAmper, New Jersey Chapter.

Hans Famularo, Esq | Internal Revenue Service

Special Counsel, Office of Chief Counsel, Small Business/Self-Employed Division, Internal Revenue Service, Laguna Niguel, CA.

Abbey Garber, Esq. | Holland & Knight LLP.

Abbey Garber is a tax attorney in Holland & Knight’s Dallas office. Mr. Garber focuses his practice on tax litigation and providing advice in connection with applying tax laws to individuals, estates, corporations and partnerships.

Mr. Garber has experience in all aspects of IRS practice, including audit, appeals, collection and litigation. He works with a range of clients, including individuals, small businesses and multi-national corporations, to resolve their tax disputes.

Prior to joining Holland & Knight, Mr. Garber served as an attorney, manager and executive for more than 30 years in the Office of Chief Counsel at the Internal Revenue Service, where he tried cases of all sizes in U.S. Tax Court, earning significant favorable opinions in fraud, tax shelter and many other cases. He also received a full Tax Court opinion in an attorneys’ fees case and prosecuted criminal tax cases in U.S. District Court as a Special Assistant United States Attorney. In addition, Mr. Garber served as the Southwest Area Team Leader in Chief Counsel, charged with ensuring collaboration and cooperation across operating divisions in a nine-state area.

Kelley C. Miller, Esq. | Reed Smith

Kelley C. Miller is a partner with Reed Smith, resident in the firm’s Washington, D.C. office. Her practice focuses on navigating her clients – publicly traded Fortune 25 companies, billion dollar privately held companies, and high-net-worth owners of successful closely held entities – through complex federal and state tax planning, estate and gift planning, and tax controversy matters. She routinely represents clients in difficult audits and examinations before the Internal Revenue Service, including representation before administrative appeals, and, when necessary, litigation of federal and state tax cases in the federal courts and, particularly, the United States Tax Court. Kelley has represented corporations, partnerships, and individuals in all phases of state and federal civil tax controversy, and has advised clients on both civil and criminal tax implications. She has appeared before the Internal Revenue Service, the New Jersey Tax Court, the D.C. Office of Tax and Revenue, the U.S. Tax Court, U.S. district courts, and the U.S. Courts of Appeals for the Fourth and Federal Circuits.

In addition to being nationally recognized for her expertise in federal tax controversy and planning, Kelley routinely advises clients in the cannabis space on issues related to COGS, IRC Section 261, and represents clients before the Internal Revenue Service in audit and examinations relating to these matters, as well as Section 280E and post-Harborside planning.

Eric L. Green, Esq. | Green & Sklarz

The focus of Attorney Green’s practice is civil and criminal taxpayer representation before the Department of Justice Tax Division, Internal Revenue Service and state Departments of Revenue Services. Eric is a nationally renowned tax expert and author/commentator of IRS civil and criminal tax matters. Having lectured to more than 70,000 practitioners on civil and criminal tax topics, he is one of the nation’s best known lecturers in continuing professional tax education.

Eric has been recognized by Connecticut Super Lawyers in the field of Tax. Attorney Green is a past Chair of the Executive Committee of the Connecticut Bar Association’s Tax Section and is a Fellow of the American College of Tax Counsel (“ACTC”). Eric also has the weekly Tax Rep Network podcast, which can be found in Apple Podcasts, ITunes, Spotify and all other podcasting platforms. He is the author of How to Build a Million Dollar Tax Representation Practice, as well as The Insider’s Guides to IRS Representation Checklists Letters & Forms, The Insider’s Guide to IRS Collections, The Insider’s Guide to Resolving Tax Debts, The Insider’s Guide to Resolving Payroll Tax Debtsand The Insider’s Guide to Tax Liens & Tax Levies. Eric is the creator, author and lecturer for the IRS Representation Certificate Program with the University of  Connecticut Business School which trains tax professionals to properly represent taxpayers before the IRS. Mr. Green has been quoted in CNN, the Wall Street Journal, The Street, USA Today, Consumer Reports – Finance, among other media sources. Eric is a contributing columnist for Bloomberg Tax and has served as a columnist for CCH’s Journal of Tax Practice & Procedure.

Eric founded Tax Rep Network, which is an online membership group that trains and supports tax professionals building their IRS Representation practices, and he founded The New England IRS Representation Conference, which is one of the largest tax conferences in the country focused on IRS Representation and controversy hot topics. Eric is also the creator of the Tax Rep App to assist tax professionals in automating their marketing efforts.

Robbin E. Caruso, CPA, CGMA | Prager Metis

Robbin E. Caruso is a Partner in the Tax Department of Prager Metis CPAs, a member of Prager Metis International Group. Robbin has been practicing in the accounting industry for over 25 years.

Robbin specializes in complex tax work and is integrally involved with the individual, fiduciary, and business tax planning and compliance, as well as assisting clients in handling various federal and state tax controversy resolution matters such as installment agreements, offers in compromise and tax audits. She also oversees accounting and financial planning matters for her high-net-worth clients.

Robbin’s passion for her work shows through her dedication to both clients and staff. She makes herself available when needed and has developed close relationships with her clients over the years. This has enabled her to provide more effective, efficient, and personalized guidance and to obtain optimal results for her clients. She is also a regular contributor to the firm’s newsletter and has been interviewed for numerous tax articles by industry publications. Robbin has spoken at continuing professional education seminars conducted for the benefit of her peers and frequently provides training to staff and clients.

Robbin is currently on the finance committee of the Canyon Creek Condominium Association. She has served on various boards and finance committees over the years, including: on the board of trustees and as chairperson of the finance committee at Pine Brook Jewish Center for over 4 years. She was also an adjunct professor at Kean University from 1993 through 2001. Courses she taught include principles, intermediate and advanced accounting, auditing, personal finance, and computer accounting systems and procedures. She has been back to Kean as guest speaker over the years.

When she is not assisting her clients, Robbin is active with a number of non-profit organizations including Rotary International, Inc., the Leukemia and Lymphoma Society, There Goes My Hero, Make A Smile Foundation, and numerous others. She also enjoys hiking, skiing, ballroom dancing, hand-built pottery, and other creative arts. Prior to joining Prager Metis, Robbin was a Managing Partner at E. Martin Davidoff & Associates, which combined with Prager Metis in November of 2018.

Darren Guillot | alliantgroup

As an alliantgroup trusted tax advisor and consultant, Mr. Guillot assists small and medium-sized businesses navigate America’s tax system to secure incentives and credits that stimulate innovation and improve products and services. He also serves them as an expert resource resolving complex compliance and appellate controversies.

Mr. Guillot recently retired from IRS after 36 years with the agency. His roles included serving as Commissioner of the IRS’ Small Business/Self Employed Division, overseeing all IRS domestic and international Collection Operations and its Operations Support functions. In his role as Commissioner, SBSE (2021 – 2022) he led IRS’ groundbreaking, successful effort using authenticated voice robotics, eliminating phone hold times for over 14 million taxpayers in less than two years. He also led the creation and oversight of IRS’ Fraud Enforcement Office, providing support and coordination for all IRS efforts in detecting and deterring tax fraud – including leading the most expansive and innovative use of data and systems analytics to address virtual currency by the civil functions of the IRS.

Darren’s extensive enforcement background at IRS was balanced by his 14 years’ experience in IRS’ Independent Office of Appeals, culminating in his creation, implementation, and top leadership of the Appeals Judicial Approach & Culture Project (2011 -2013) and its resulting policies and procedures in use to this day. He began his IRS career as a revenue officer and holds a bachelor’s degree from the University of Holy Cross, is a fellow of the Loyola University Institute of Politics and was awarded the Certificate in Public Leadership by the Brookings Institution.

Carmela G. Walrond, Esq., CPA | JLD Tax Resolution Group

Prepare and review federal and state tax returns for corporations, partnerships, small businesses and individual taxpayers, including high net worth taxpayers.

Represent clients in IRS and state audit examinations. Experience in negotiating with the IRS on various tax issues for the benefit of clients or companies.

Michelle F. Schwerin, Esq., CPA | Neill Schwerin Boxerman, PC.

Larry A. Campagna, Esq. | Chamberlain, Hrdlicka, White, Williams & Aughtry, PC.

Larry Campagna has established a reputation as an authoritative litigator in matters of business litigation and white collar criminal defense, as well as federal, state and local tax controversies. For more than 45 years, he has resolved thousands of civil and criminal litigation matters, many of which involved sophisticated and complex legal issues that established precedent in courts at the federal, state and local levels.

Highlights of Mr. Campagna’s career include: representing the first taxpayer to be awarded attorneys’ fees by the Fifth Circuit Court of Appeals; serving as lead counsel in one of the largest project cases in the history of the United States Tax Court; and successfully defending one of the world’s largest accounting firms in a tax malpractice case.

Mr. Campagna teaches a course in the law of Tax Crimes and Money Laundering as an Adjunct Professor at the University of Houston Law Center. He has served the American Bar Association Section of Taxation as Chair of the Employment Taxes Committee; as Chair of the Subcommittee on IRS Investigations and Procedures of the Committee on Civil and Criminal Tax Penalties; and as Chair of a Task Force on Offshore Credit Card Cases of the Civil and Criminal Tax Penalties Committee.

Barbara T. Kaplan, Esq | Greenberg Traurig

Barbara T. Kaplan is Co-Chair of the Global Tax Practice and has been named one of the top 50 women lawyers in New York City by Super Lawyers magazine, and focuses her tax litigation practice on domestic and foreign corporations, partnerships, and individuals in federal, state, and local tax examinations, controversies and litigation, including administrative and grand jury criminal tax investigations.

Brian C. McManus, Esq. | Latham & Watkins

Brian McManus, Chair of Latham & Watkins’ Boston Tax Department, advises companies and high net-worth individuals in all phases of civil and criminal tax disputes.

Widely recognized as one of the nation’s leading tax litigators, Mr. McManus helps clients confidentially resolve a range of controversies — from Internal Revenue Service (IRS) audits and appeals to litigation before federal and state courts throughout the United States. He delivers clear and technically astute counsel to a diverse mix of American and international clients, including multinational and Fortune 500 corporations from diverse industries (such as technology, banking, insurance, energy, pharmaceuticals, airlines, entertainment, and retail), global professional services firms, international charitable organizations, trust companies, and offshore corporate providers.

Drawing on nearly two decades of “inside the Beltway” experience, Mr. McManus regularly handles controversy matters with broader tax policy implications. His Washington ties include serving as an Adjunct Professor of Law at Georgetown University Law Center where he currently teaches IRS Practice and Procedure in the graduate tax (LLM) program.

Mr. McManus brings a winning track record in court handling some of the nation’s largest tax disputes. His work encompasses all areas of federal and state taxation, with an emphasis on disputes involving cross-border and international tax matters, sophisticated corporate transactions, enterprise and asset valuations, transfer pricing, partnerships, tax-exempt organizations, oil and gas taxation, tax shelters, promoter penalty defense, and cryptocurrency. He also frequently handles sensitive tax matters involving allegations of fraud and potential criminal tax charges, as well as voluntary disclosures of domestic and offshore filing errors. Mr. McManus is admitted to practice before the US Court of Appeals for Federal Circuit, the US Tax Court, the US Court of Federal Claims, and the US District Court for the District of Massachusetts.

Mr. McManus, who serves as a Vice Chair of the American Bar Association (ABA) Tax Section’s Civil and Criminal Tax Penalties Committee, regularly speaks at national tax conferences and on podcasts. He is also the author of numerous tax controversy-focused articles.

Trisha M. Turner | Internal Revenue Service

Senior Advisor, Office of the Digital Assets Initiative, Internal Revenue Service, Washington, DC.

DAY 1: THURSDAY, JUNE 27, 2024

TAX COMPLIANCE AND ENFORCEMENT UPDATE: PART I | 8:30am – 8:45am

Voluntary compliance and enforcement of the tax law are at the heart of our tax system. Over the past several years, the IRS and DOJ have been challenged to come up with new and more efficient ways to ensure that all taxpayers pay the correct amount of tax. These panels provide an update on new developments and priorities across various divisions of the government.
Caroline D. Ciraolo, Esq., Partner, Kostelanetz, Washington, DC
Miri Forster, Esq., Partner and National Tax Controversy Leader, EisnerAmper, New York, NY

WHAT’S NEXT FOR THE IRS? AN UPDATE FROM SENIOR IRS EXECUTIVES | 8:45am – 9:45am

There is a lot going on at the IRS! The IRS announced a new leadership structure to align to its new priorities, funding from the IRS Inflation Reduction Act is being used to support better customer service, increased enforcement, and modernization, and digital transformation is on the horizon. Hear directly from senior IRS executives as they discuss the plans for the future, hiring trends, the compliance and enforcement focus, and other critical areas.

Moderator: Sharon Katz-Pearlman, Esq., Shareholder, Greenberg Traurig, New York, NY
Lia Colbert, Commissioner, Small Business/Self-Employed Division, Internal Revenue Service, Washington, DC
Heather Maloy, Esq., Chief Taxpayer Compliance Officer, Internal Revenue Service, Washington, DC
Holly O. Paz, Esq., Commissioner, Large Business and International Division, Internal Revenue Service, Washington, DC

CRIMINAL TAX ENFORCEMENT UPDATE | 9:45am – 10:45am

With the increase in the IRS enforcement budget coupled with the recent focus on fraud enforcement, tax professionals are preparing for a rise in criminal tax investigations and prosecutions. This panel features Guy Ficco, new Chief of IRS Criminal Investigation, and top criminal tax defense experts on the latest trends and developments in criminal tax. Topics include enforcement priorities, technological innovations and data analytics, public-private partnerships, IRS funding and developments in cryptocurrency enforcement. Practitioners share practical tips on working with IRS-CI and tips on how to navigate the sensitivities of an IRS criminal investigation.

Moderator: Don Fort, CPA, Director of Investigations, Kostelanetz, Washington, DC
Guy Ficco, Chief, Criminal Investigation Division, Internal Revenue Service, Washington, DC
Caryn Finley, Esq., Assistant US Attorney, US Attorney’s Office, Western District of North Carolina, Charlotte, NC
Jason B. Freeman, Esq., Managing Member, Freeman Law PLLC, Dallas, TX
Jeremy H. Temkin, Esq., Principal, Morvillo Abramowitz Grand Iason & Anello PC, New York, NY

Break | 10:45am – 10:55am

US DEPARTMENT OF JUSTICE TAX DIVISION UPDATE | 10:55am – 11:25am

Moderator: Michael J. Desmond, Esq., Partner, Gibson, Dunn & Crutcher, Los Angeles, CA and Washington, DC
David A. Hubbert, Esq., Principal Deputy Assistant Attorney General, Tax Division,
US Department of Justice, Washington, DC

DIVERSITY, INCLUSION AND ELIMINATION OF BIAS CREDIT: ELIMINATING BIAS IN REPRESENTING THE IMMIGRANT WORKER AND THEIR EMPLOYER | 11:25am – 12:15pm

Immigrant workers support America’s business community. Rather than taking jobs away from American workers, studies show that immigrant workers create new jobs by forming new businesses, spending income on American goods and services, and paying more than $90 billion in taxes each year. Despite these contributions, immigrant workers and their American employers face challenges and implicit bias in their efforts to comply with US tax laws. This panel explains how immigrant workers fit within our tax framework, common issues that arise, the existence and consequences of implicit bias, and paths to compliance for both the worker and the employer.

Moderator: Nina E. Olson, Esq., Executive Director, Center for Taxpayer Rights, Washington, DC
Frank Agostino, Esq., Founder & President, Agostino & Associates, PC, Hackensack, NJ
Jacqueline Laínez Flanagan, Esq., Deputy Director, Center for Taxpayer Rights, Washington, DC
Carlos F. Ortiz, Esq., Partner, BakerHostetler, New York, NY
Anna Tavis, Esq., Staff Attorney, Brooklyn Legal Services, Brooklyn, NY

Lunch | 12:15pm – 1:00pm

BREAK OUT SESSIONS | 1:00pm – 1:50pm

TRACK II

THINK GLOBALLY: INTERNATIONAL TAX ENFORCEMENT AND DISPUTES

Understanding international tax reporting and filing obligations is vital to businesses operating in a global environment. With the push to close tax gaps and crack down on aggressive tax avoidance, the increase in collaboration among treaty partners, and the surge in tax examinations and investigations, it is more important than ever to stay up to date on the latest developments in international tax enforcement and disputes. This panel of international tax experts addresses recent developments in cross-border tax matters including transfer pricing, double taxation, exchange of information, international audit tools and the like.

Moderator: Heather Fincher, Esq., Associate, Kostelanetz, Washington, DC
David Farhat, Esq., Partner, Skadden Arps Slate Meagher & Flom, Washington, DC
Joshua Odintz, Esq., Partner, Holland & Knight, Washington, DC
Christopher Slade, Esq., Partner, Aird & Berlis, Toronto, Canada

Break | 1:50pm – 2:10pm

BREAK OUT SESSIONS | 2:10pm – 3:00pm

THE ADMINISTRATIVE PROCEDURE ACT v. THE IRS: WHICH REGULATIONS, RULES, AND NOTICES WILL SURVIVE?

Ever since the Supreme Court rejected that Treasury Regulations are reviewed differently in Mayo Foundation v. United States, 562 U.S. 44 (2011), challenges to tax regulations and IRS notices have proliferated. Courts have now developed a full body of jurisprudence regarding application of the Administrative Procedure Act (“APA”) to tax cases. Have we reached the end of “tax exceptionalism”? How will the APA apply to the blizzard of new regulations under the TCJA and old regulations promulgated in a pre-Mayo world? This panel addresses these questions and explores the current state of the law on the APA as it applies to tax including the Loper Bright Enterprises, Relentless Inc., and Corner Post Supreme Court cases.

Moderator: Andrew Weiner, Esq., Counsel, Kostelanetz, Washington, DC
David W. Foster, Esq., Partner, Kirkland & Ellis, Washington, DC
Katherine Jordan, Esq., Director of Tax Controversy, GBX Group, Cleveland, OH
Michelle Abroms Levin, Esq., Shareholder, Dentons Sirote, Huntsville, AL

Break | 3:00pm – 3:20pm

BREAK OUT SESSIONS | 3:20pm – 4:10pm

TRACK II

YOUR CLIENT EARNS MORE THAN $400,000 – EFFECTIVELY MANAGING IRS EXAMINATIONS OF THE HIGH INCOME/HIGH NET WORTH TAXPAYER

Secretary Yellen and the IRS have made it clear that increased audits and additional resources will focus on US taxpayers with annual income of more than $400,000, targeting “high-end noncompliance” involving wealthy individuals, large corporations, complex pass-through entities, and exempt organizations. IRS Large Business & International, working with other IRS operating divisions, are investing resource in these efforts and announcing new compliance campaigns including but not limited to corporate jet deductions, art donations and sports industry losses. This panel of expert practitioners provides an overview of the IRS high-end enforcement efforts, issues being raised in related audits and investigations, and best practices in defending your clients.

Moderator: Emily P. Hughes, PC, Esq., Partner, Kirkland & Ellis, Washington, DC
Niles A. Elber, Esq., Member, Caplin & Drysdale, Chartered, Washington, DC
S. Starling Marshall, Esq., Partner, Crowell & Moring, New York, NY
Fran Obeid, Esq., Founder, MFO LAW, PC, New York, NY

Break | 4:10pm – 4:30pm

BREAK OUT SESSIONS | 4:30PM – 5:30PM

CHALLENGING CIVIL PENALTIES-RECENT DEVELOPMENTS

The IRS has substantially increased the assertion and assessment of civil penalties, arguably to encourage compliance but often in cases where the punishment far exceeds the violation. While staggering penalties for filing late international information returns and Reports of Foreign Bank and Financial Accounts are often front-page news, taxpayers also are challenging erroneous refund penalties, Affordable Care Act and other domestic information reporting penalties, valuation penalties, and delinquency penalties. The IRS is even considering penalties under the economic substance doctrine. This panel explores recent civil penalty developments, available defenses, and best practices, and discusses recent decisions and pending cases including Lu v. Commissioner, Mukhi v. Commissioner, Groves v. Commissioner, Ueland v. United States, Farhy v. Commissioner, and more!

Moderator: Michel R. Stein, Esq., Principal, Hochman Salkin Toscher Perez, PC, Beverly Hills, CA
Byung Hyuk Min, Esq., Associate, Agostino & Associates, Hackensack, NJ (invited)
Daniel N. Price, Esq., Law Offices of Daniel N. Price, San Antonio, TX
Lawrence A. Sannicandro, Esq. Partner, McCarter & English, Newark, NJ
Zhanna A. Ziering, Esq., Member, Moore Tax Law Group, New York, NY

DAY 2: FRIDAY, JUNE 28, 2024

ETHICS CREDIT: HANDLING EMPLOYEE RETENTION CREDIT AUDITS AND INVESTIGATIONS—COLORING IN THE LINES | 8:45am – 9:45am

Claims for Employee Retention Credits (“ERCs”) have proliferated exponentially. To address questionable claims, the IRS recently announced a Voluntary Withdrawal and Voluntary Disclosure Program to give taxpayers with possibly ineligible claims an opportunity to come forward, cooperate with the IRS, and, in return, minimize their financial exposure including penalties. The IRS is also aggressively auditing ERC claims and pursuing penalties and criminal prosecutions for ERC related abusive schemes and fraud. This panel of experienced practitioners discusses the IRS’s targeted enforcement efforts, explains how to spot red flags indicating abuse of the ERC, describes the penalties that apply to taxpayers, promoters, and practitioners for erroneously claiming ERC credits, and addresses the filing of the corresponding wage reduction on an income tax return.

Moderator: Thomas A. Cullinan, Esq., Shareholder, Chamberlain, Hrdlicka, White, Williams & Aughtry, PC, Atlanta, GA
Sandra R. Brown, Esq., Principal, Hochman Salkin Toscher Perez PC, Beverly Hills, CA
Sharyn M. Fisk, Esq., Director, Office of Professional Responsibility, Internal Revenue Service, Washington, DC
Eric Hylton, National Director, alliantGroup, Washington, DC
Daniel Mayo, Esq., Partner, WithumSmith+Brown, PC, Red Bank, NJ

IRS WHISTLEBLOWER OFFICE UPDATE | 9:45am – 10:10am

With the enactment of Section 7623, claims for whistleblower awards have skyrocketed and the IRS Whistleblower Office has a full plate of work: processing new submissions; managing open claims and issuing awards. To ensure it is successfully meeting these challenges, the Whistleblower Office has embarked on an ambitious Whistleblower Program Improvement Plan. Key goals of the improvement plan include: increasing high-value claims coming in; improving the Whistleblower’s Office ability to identify such claims; and better tracking of such claims through improved systems – and efforts to pay awards sooner. This panel provides an update from the IRS Whistleblower Office on recent reform efforts, highlights issues the IRS is particularly interested in hearing more about from whistleblowers, what makes for a good whistleblower submission, as well as touches on recent court decisions addressing this important practice area.

Moderator: Dean Zerbe, Esq. Partner, Zerbe, Miller, Fingeret, Frank & Jadav, Houston, TX
John W. Hinman, Director, Whistleblower Office, Internal Revenue Service, Washington, DC

IRS COLLECTION UPDATE | 10:10am – 10:35am

Issuance of IRS collection notices have resumed and IRS collection efforts from high income non-filers and those with outstanding tax debt have brought in millions of dollars since FY 2023. This panel provides an update from IRS Collection on recent collection efforts, availability of new collection tools and expectations for the future that impacts every tax practice.
Moderator: Beverly Winstead, Esq., Principal, Law Office of Beverly Winstead, Baltimore, MD
Mary Beth Murphy, Director of Collections, North Atlantic Territory, Small Business/Self-Employed Division, Internal Revenue Service, Washington, DC

TAXPAYER ADVOCATE UPDATE | 10:35am – 11:00am

Erin Collins became the National Taxpayer Advocate (“NTA”) on March 30, 2020, at the outset of the COVID-19 pandemic. With the IRS pushed to its breaking point, Collins and her team continued their dual focus on addressing systemic issues (of which there were many) and handling individual taxpayer cases (of which there were even more). Hear about the lessons learned over Collins’ past four years in the role and the NTA’s priorities and vision for the future of the newly funded IRS.

Moderator: Todd Welty, Esq., Partner, Kostelanetz, Atlanta, GA
Erin M. Collins, Esq., National Taxpayer Advocate, Internal Revenue Service, Washington, DC

Break | 11:00am – 11:15am

UPDATES FROM THE IRS OFFICE OF CHIEF COUNSEL AND US TAX COURT | 11:15am – 12:15pm

The IRS Office of Chief Counsel and the US Tax Court both play important roles in the resolution of cases that have not been resolved at audit or in appeals. This panel provides insight into cases involving the Office of Chief Counsel and the US Tax Court, challenges presented by those cases, and how those challenges are being addressed.

Moderator: Jennifer Breen, Esq., Partner, Morgan Lewis & Bockius, Washington, DC
Moderator: Diana L. Erbsen, Esq., Partner, DLA Piper, New York, NY
The Hon. Elizabeth A. Copeland, Judge, United States Tax Court, Washington, DC
Marjorie A. Rollinson, Esq., Chief Counsel, Office of Chief Counsel, Internal Revenue Service, Washington, DC

Lunch | 12:15pm – 1:30pm

BREAK OUT SESSIONS | 1:30pm – 2:20pm

TRACK II

SURVIVING AN AUDIT AND ADMINISTRATIVE APPEALS UNDER THE CENTRALIZED PARTNERSHIP AUDIT REGIME

The Bipartisan Budget Act (“BBA”) was signed into law November 2, 2015, replacing the audit and collection procedures for partnerships under the Tax Equity and Fiscal Responsibility Act of 1982 (“TEFRA”) for tax years beginning January 2018. BBA audits are on the rise, and revenue agents and tax professionals are working together to navigate these choppy waters. This panel explains the centralized partnership audit regime and recent partnership audit trends, notices to expect from the IRS, actions to take during the audit, methods to challenge proposed adjustments, and the impact on the individual partners.

Moderator: Miri Forster, Esq., Partner and National Tax Controversy Leader, EisnerAmper, New York, NY
Hans Famularo, Esq., Special Counsel, Office of Chief Counsel, Small Business/Self-Employed Division, Internal Revenue Service, Laguna Niguel, CA
Abbey Garber, Esq., Partner, Holland & Knight, Dallas, TX
Kelley C. Miller, Esq., Partner, Reed Smith, Washington, DC

Break | 2:20pm – 2:40pm

BREAK OUT SESSIONS | 2:40pm – 3:30pm

TRACK II

CREATIVE COLLECTION ALTERNATIVES

Issuance of collection notices have resumed in full force and the IRS has increased its efforts to pursue high net worth taxpayers with outstanding tax debt. One of the most common questions raised by taxpayers faced with potential or assessed tax liabilities is: What are my options? A simple question that requires the tax professional to explain the numerous and often complex paths to resolving federal tax liabilities. While navigating the numerous options, taxpayers must address ever-increasing enforcement actions, including, but not limited to, the filing of Notices of Federal Tax Lien, levies and wage garnishments, responsible person investigations, and nominee or alter ego liens. This panel reviews a taxpayer’s right to an administrative appeal of collection enforcement, the procedures for pursuing collection appeals, arguments that can be raised, best practices, and tips of the trade.

Moderator: Eric Green, Esq., Partner, Green & Sklarz, New Haven, CT
Robbin E. Caruso, CPA, CGMA, Partner, Prager Metis, Cranbury, NJ
Darren John Guillot, National Director, alliantGroup, Washington, DC
Carmela G. Walrond, Esq., Partner, JLD Tax Resolution Group, Union City, NJ

Break | 3:30pm – 3:50pm

BREAK OUT SESSIONS | 3:50pm – 4:50pm

TRACK II

PREPARING FOR INCREASED CRYPTOCURRENCY REGULATION AND ENFORCEMENT IN UNCERTAIN TIMES

The cryptocurrency industry is constantly changing, and its underlying technologies are undeniably confusing. Faced with these obstacles, the IRS has issued informal guidance on discrete and nuanced tax issues and added questions about digital asset transactions to entity tax returns, Treasury has proposed new information reporting rules, and regulatory scrutiny is tightening from all directions. This panel discusses the latest issues involving digital assets and highlights important considerations for tax practitioners.

Moderator: Michelle F. Schwerin, Esq., CPA, Shareholder, Neill Schwerin Boxerman, PC, St. Louis, MO
Larry A. Campagna, Esq., Managing Shareholder, Chamberlain, Hrdlicka, White, Williams & Aughtry, PC, Houston, TX
Barbara T. Kaplan, Esq., Shareholder, Greenberg Traurig, New York, NY
Brian C. McManus, Esq., Partner, Latham & Watkins, Boston, MA
Trisha M. Turner, Senior Advisor, Office of the Digital Assets Initiative, Internal Revenue Service, Washington, DC