18th Annual Tax Controversy Forum 2026 – Track II (Presented by NYU School of Professional Studies)

Caroline D. Ciraolo, Esq., Partner | Kostelanetz

Caroline D. Ciraolo, former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division, is a partner with Kostelanetz LLP and founder of its Washington, D.C. office. Her practice focuses on federal and state civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, and representing individuals and entities in criminal tax investigations and prosecutions. She also serves as a consulting and testifying expert witness and as an independent mediator in tax-related administrative proceedings and litigation. During her tenure with the Justice Department, Caroline was actively involved in all aspects of Tax Division operations and responsible for approximately 500 employees, including more than 360 attorneys across 14 civil, criminal, and appellate sections.

• Education & Credentials

Caroline earned an LL.M. in Taxation from the University of Baltimore School of Law in 1994, a J.D. with Honors from the University of Maryland School of Law in 1993, and a B.S. in Finance with Honors, cum laude, from The College of New Jersey in 1990. She is admitted to practice in Maryland (1993), Pennsylvania (1995), New Jersey (1995), and the District of Columbia (1995). Her court admissions include the U.S. Tax Court; the U.S. District Court for the District of Maryland; the U.S. Court of Federal Claims; the U.S. Courts of Appeals for the Second, Fourth, Ninth, and Federal Circuits; and the U.S. Supreme Court.

• Recognition & Leadership

Caroline is recognized by Chambers for USA: Tax Fraud (Nationwide) (Band 1), Tax Controversy – Nationwide (Band 2), District of Columbia: Tax (Band 1), and High Net Worth: Tax-Private Client – USA (Band 1). She is named a Leading Lawyer by Legal 500 and is recognized by Benchmark Litigation, ITR World Tax (Tax Controversy, World Tax – Highly Regarded, and Women in Tax Leader), and Super Lawyers in both D.C. and Maryland (including Top 10 in Maryland and a Maryland cover story in 2013). She is recognized in Best Lawyers in America for Litigation and Controversy – Tax, Tax Law, and Criminal Defense: White Collar, and has been named Lawyer of the Year for Litigation and Controversy – Tax (D.C. 2022, 2024, and 2026; Maryland 2012) and for Tax Law (D.C. 2025). She received the Euromoney Legal Media Group’s Americas Women in Business Law Awards (Best in Tax Dispute Resolution) (2014) and was named to The Daily Record’s Top 100 Women Circle of Excellence. She is also a recipient of the ABA Section of Taxation’s Janet Spragens Pro Bono Award, the IRS Chief Counsel Award (the highest honor that office can confer), and the Tax Excellence Award from the Taxation Section of the Maryland State Bar Association.

• Professional Involvement

Caroline is former President of the American College of Tax Counsel and former Chair of the Civil & Criminal Tax Penalties Committee of the American Bar Association Section of Taxation. She served as the ABA Tax Section’s inaugural Vice Chair for Membership, Diversity, and Inclusion, and inaugural Chair of the Loretta Collins Argrett Fellowship Program. She is a Fellow of the American College of Tax Counsel (Immediate Past President 2021-2022, Vice President 2020-2021, Secretary/Treasurer 2018-2020, and Regent for the 4th Circuit 2017-2018) and a Fellow of the Litigation Counsel of America and the Maryland Bar Foundation. She also served as an instructor with the IRS Military Volunteer Income Tax Assistance program at Ft. George G. Meade. She is an Adjunct Professor at the Georgetown University Law Center, teaching International Tax Controversies and Criminal Tax Law and Procedure, and previously taught Tax Practice and Procedure and Criminal Tax in the University of Baltimore School of Law Graduate Tax Program.

• Experience

Caroline served as Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division (February 25, 2015 – July 15, 2016), as well as Principal Deputy Assistant Attorney General (January 12, 2015 – January 20, 2017), Deputy Assistant Attorney General for Criminal Matters (October 5, 2015 – January 20, 2017), and Deputy Assistant Attorney General for Policy and Planning (January 12, 2015 – January 20, 2017). During her tenure, she was actively involved in all aspects of Tax Division operations and was responsible for approximately 500 employees, including more than 360 attorneys across 14 civil, criminal, and appellate sections. Earlier in her career, she served as Attorney Advisor to the Honorable Stanley J. Goldberg of the U.S. Tax Court (August 1994 – August 1996) in Washington, D.C. As a partner with Kostelanetz LLP and founder of its Washington, D.C. office, her practice focuses on federal and state civil tax controversies, sensitive audits, administrative appeals, litigation, internal investigations, and criminal tax investigations and prosecutions, and she serves as a consulting and testifying expert witness and independent mediator in tax-related matters.

Michael J. Desmond, Esq., Member and Tax Department Chair | Miller & Chevalier, Chartered

Michael J. Desmond is a Member at Miller & Chevalier, where he serves as Chair of the Tax practice and Practice Co-Lead of Tax Controversy & Litigation. His practice covers a broad range of federal tax matters with a focus on administrative tax policy, tax controversy, and litigation. He represents clients in approaches to the Internal Revenue Service (IRS) and the U.S. Department of the Treasury on administrative rulemaking matters and matters relating to tax administration and enforcement, seeking clarity on the application of federal tax laws. He also represents clients before the examination divisions of the IRS, the IRS Independent Office of Appeals, and in the U.S. Tax Court, federal district courts, the Court of Federal Claims, and federal courts of appeal. His clients have included businesses and individuals across a wide range of industries, including real estate, financial services, publishing, technology, medical services and devices, and entertainment. Clients quoted in Chambers USA have described him as “very smart, strategic, and knowledgeable of tax law,” “responsive and insightful,” noting that his knowledge of complex matters is incredibly valuable.

• Education & Credentials

Mike earned 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 his B.A. from the University of California, Santa Barbara in 1990. He is admitted to practice in California, the District of Columbia, and New York. His court admissions include the United States Tax Court; the U.S. Courts of Appeals for the Federal, Fourth, Seventh, Ninth, and Tenth Circuits; the U.S. District Courts for the District of Columbia, the Central District of California, and the Northern District of California; and the U.S. Court of Federal Claims.

• Recognition & Leadership

Mike has been recognized in The Best Lawyers in America® for Tax Law from 2012 through 2025 and was named Lawyer of the Year for Tax Litigation and Controversy in 2023. He is ranked in Chambers High Net Worth USA for Tax: Private Client (Nationwide) from 2023 through 2025 and in Chambers USA for Tax: Controversy (Nationwide) from 2008 through 2019 and 2023 through 2025. He is recognized by Legal 500 for Tax: U.S. Taxes: Contentious from 2008 through 2018 and 2022 through 2025, including Hall of Fame honors in 2024 and 2025, and was named to the Lawdragon: 500 Leading Global Tax Lawyers Guide in 2025. His government service was recognized with the IRS Commissioner’s Award (2008, 2021), the IRS Chief Counsel’s Award (2008), the Treasury Secretary’s Honor Award (2007), and the U.S. Department of Justice, Tax Division Award for Sustained Superior Performance (1998).

• Professional Involvement

Mike currently serves as President of the American College of Tax Counsel and as Vice Chair of Government Relations for the Tax Section of the American Bar Association. He is a former Chair of the Committee on Government Submissions, the Standards of Tax Practice Committee, and the Tax Shelters Committee within the ABA Tax Section, and he serves as a Trustee of the Southern Federal Tax Institute. He previously served as an adjunct professor at Georgetown University Law Center and has been a guest lecturer at law schools around the country.

• Experience

Prior to joining Miller & Chevalier, Mike was a partner with a global law firm. Before that, he served as the 48th Chief Counsel of the IRS, nominated by the president and confirmed by the Senate, where he was the principal legal officer for the IRS, overseeing a staff of nearly 1,500 lawyers responsible for interpreting and advising on all aspects of federal tax law. During his tenure, the Office issued more than 100 sets of proposed and final regulations implementing the Tax Cuts and Jobs Act of 2017 and published dozens of guidance items relating to the COVID-19 pandemic, while litigating nearly 25,000 cases pending in the U.S. Tax Court and working with the DOJ Tax Division on cases in other courts, including the U.S. Supreme Court. He previously served as Tax Legislative Counsel at the Treasury, the principal legal advisor to the Secretary and Assistant Secretary (Tax Policy) on all domestic aspects of federal tax law other than employee benefits, working closely with the congressional tax writing committees. Earlier in his career, he served as a Trial Attorney in the DOJ Tax Division, litigating dozens of cases throughout the western U.S., and as a law clerk to the Honorable Ronald S.W. Lew of the U.S. District Court for the Central District of California. In private practice, he has been counsel of record in numerous docketed tax matters, litigating many to published decision on issues including transferee liability, debt versus equity treatment of partnership investments, the “property for services” rules, partnership refund claim requirements, fraud penalties, and the valuation of customer-based intangibles.

Hon. Frank J. Bisignano, Chief Executive Officer | Internal Revenue Service

Hon Frank J. Bisignano is the first Chief Executive Officer of the Internal Revenue Service, managing an agency that collected approximately $5.1 trillion in tax revenue in Fiscal Year 2024 — revenue that consistently generates about 96% of the funding that supports the federal government’s operations each year. He brings to this role extensive leadership experience from several decades in the financial services sector. Widely recognized for his expertise in operational management and technology innovation, he has consistently driven growth, improved customer service, and led complex organizations through modernization and digital transformation. As IRS CEO, he works to advance the IRS mission by sharpening its focus on three priorities: improving collections, safeguarding privacy, and enhancing customer service — goals that guide how the agency delivers better outcomes for taxpayers and strengthening the IRS for the future.

• Recognition & Leadership

Mr. Bisignano is widely recognized for his expertise in operational management and technology innovation, and throughout his career he has consistently driven growth, improved customer service, and led complex organizations through modernization and digital transformation. He started his career on Wall Street and became the youngest Senior Vice President of Shearson Lehman/American Express at age 25. Following the September 11, 2001 attacks on New York’s World Trade Center, during which he was with Citigroup, he led the relocation of more than 16,000 displaced Citigroup employees and became a founding member and board leader of the 9/11 Memorial & Museum.

• Professional Involvement

Alongside his duties as IRS CEO, Mr. Bisignano continues to serve as the Commissioner of the Social Security Administration, a position he assumed in May 2025, where he has taken swift action to transform that agency into a premier service organization delivering best-in-class service to the American people. He also serves as a founding member and board leader of the 9/11 Memorial & Museum.

• Experience

Prior to his government service, Mr. Bisignano was CEO of Fiserv, the world’s largest financial services and payment technology company. Before Fiserv, he was the Chairman and CEO of First Data, where he transformed the 43-year-old company into a technology innovator, industry collaborator, and commerce enabler for the 21st century. He started his career on Wall Street and was the youngest Senior Vice President of Shearson Lehman/American Express at age 25. He later became the co-Chief Operating Officer for J.P. Morgan Chase and the CEO of its Mortgage Banking unit. He also held several roles at Citigroup, and was with Citigroup on September 11, 2001, when terrorists attacked New York’s World Trade Center; in the aftermath, he led the relocation of more than 16,000 displaced Citigroup employees.

Sharon Katz-Pearlman, Esq., Shareholder | Greenberg Traurig

Sharon Katz-Pearlman is a Shareholder at Greenberg Traurig, LLP, based in New York, who focuses her practice on the representation of large multinationals, partnerships, high-wealth individuals, and other taxpayers before the Internal Revenue Service (IRS) on both domestic and cross-border issues, across all industries. She represents clients from the pre-exam phase — including voluntary disclosures and pre-filing agreements — through examination, appeals, and into litigation if necessary, and has wide-ranging experience with resolution of transfer pricing issues at the examination and IRS Appeals level as well as with Competent Authority proceedings, seeking a Mutual Agreement Procedure (MAP) agreement and/or an Advanced Pricing Agreement (APA). In addition to traditional representation before the IRS, she represents clients using the full range of IRS Alternative Dispute Resolution tools, advises large companies on the IRS’s Compliance Assurance Program (CAP) and other IRS specialty programs, and advises clients on application to and participation in the OECD’s International Compliance Assurance Programme (ICAP) process. She is a member of the firm’s Tariff Task Force, a multidisciplinary initiative that guides clients through tariff refund matters, tax, litigation, and M&A activity spurred by global shifts. Sharon brings over 30 years of experience in federal tax controversy, gained in both private and government practice.

• Education & Credentials

Sharon earned an LL.M. from New York University School of Law, a J.D., cum laude, from the Benjamin N. Cardozo School of Law, and a B.A., cum laude, from Barnard College, Columbia University. She is admitted to practice in New York and before the U.S. Tax Court.

• Recognition & Leadership

Sharon has been shortlisted by The Legal Benchmarking Group for its “Women in Business Awards,” including North America Transfer Pricing Lawyer of the Year (2026) and North America Tax Lawyer of the Year (2025). She is listed in The Best Lawyers in America for Tax Law (2025-2026) and in Lawdragon’s “500 Leading Global Tax Lawyers” (2025). She is recognized by International Tax Review as a “Controversy Leader” in its Comprehensive Guide to the World’s Leading Tax Controversy Advisors, in its Women in Tax Leaders Guide (2025-2026), and as a World Tax Leader, and is listed in Euromoney’s Expert Guides for “Women in Business Law.” While with the IRS Office of Chief Counsel, she earned the National Attorney of the Year Award, given annually to one attorney for outstanding contribution to the Office.

• Professional Involvement

Sharon is a Fellow of the American College of Tax Counsel and an Adjunct Professor of Law at NYU Law School, where she teaches Civil Tax Controversies & Litigation. She is a former member (four-year term) of the United Nations Tax Subcommittee on Dispute Avoidance, Resolution and the Mutual Agreement Process, under the direction of the United Nations Committee of International Tax Experts on International Cooperation in Tax Matters. She serves on the Board of Overseers of the Cardozo School of Law, Yeshiva University (2023-Present), and has served on the Law360 Tax Authority Federal Editorial Advisory Board (2024) and International Editorial Advisory Board (2023). She is a member of the National Association of Women Lawyers, the American Bar Association, the New York State Bar Association, and the Federal Bar Association. She is often quoted in tax publications such as Tax Notes and frequently speaks on tax controversy topics at industry conferences including the Tax Executives Institute (TEI), the American Bar Association (ABA), the Practicing Law Institute (PLI), the NYU Tax Controversy Forum, and the Tax Council Policy Institute (TCPI).

• Experience

Immediately prior to joining Greenberg Traurig, Sharon served as the national and global practice leader of the Tax Controversy & Dispute Resolution practice at a Big Four accounting firm. She was with KPMG, LLP from 1993 to 2022, where she held roles including Co-National Principal in Charge, Tax Controversy & Dispute Resolution, Washington National Tax; National Principal in Charge, Tax Controversy & Dispute Resolution; Northeast Area Principal in Charge, Tax Controversy Services; and Senior Manager, Tax Controversy Services. From 2008 to 2022, she served as Global Head of the Tax Dispute Resolution and Controversy Network at KPMG International. Earlier in her career, she was a litigator for the IRS Office of Chief Counsel from 1986 to 1993, serving as a Special Litigation Attorney (and recipient of the National Attorney of the Year Award in 1989) as well as a Trial Attorney/Senior Trial Attorney. She has served as an Adjunct Professor of Law in the LLM Program at New York University School of Law from 2017 to the present.

Lia Colbert, Commissioner, Small Business/Self-Employed Division | Internal Revenue Service

Amalia “Lia” Colbert serves as Commissioner of the Small Business/Self-Employed (SB/SE) Division of the Internal Revenue Service. In this role, she oversees taxpayer programs and services affecting the nation’s small business and self-employed individuals, providing oversight of SB/SE’s $2.34 billion budget and executive leadership to a staff of over 20,000 employees responsible for service and enforcement programs for 57 million taxpayers who file personal, corporate, flow-through, employment, and excise and estate and gift tax returns. She also has oversight for two Servicewide offices that focus on IRS civil efforts in detecting and deterring tax fraud, and analyzing and identifying abusive tax transactions, tax schemes, and emerging abusive schemes.

• Recognition & Leadership

Her leadership is reflected in her progressive executive roles within the IRS, including her current position as SB/SE Commissioner, where she oversees a $2.34 billion budget and a staff of over 20,000 employees, and earlier as Deputy Chief of the IRS Independent Office of Appeals, where she worked closely with the Chief of Appeals in leading nationwide programs designed to enable Appeals employees to resolve tax controversies without litigation on a fair and impartial basis.

• Experience

Lia’s career has been built within the Internal Revenue Service across a progression of executive and leadership roles. She currently serves as SB/SE Commissioner. Previously, she served as Deputy Chief of the IRS Independent Office of Appeals, leading nationwide programs to resolve tax controversies without litigation. Prior to that, she served in dual roles as the IRS Chief of Staff and the Taxpayer First Act (TFA) office executive lead; as Chief of Staff, she worked closely with the IRS Commissioner and senior leadership team to implement strategic priorities and initiatives critical to tax administration, and as TFA office executive lead, she oversaw Servicewide implementation of TFA provisions and delivery of the TFA Report to Congress, bringing together a comprehensive taxpayer experience strategy, a holistic training strategy, and a modernized IRS organizational structure. She also previously held positions within the IRS Human Capital Office, including senior advisor to the HCO; Deputy Director, Employment, Talent and Security; and Director, Workforce Relations. She started her leadership journey in the Office of Appeals as a team manager, Collection Area Director, and Appeals Training Director.

Edward R. Killen, Esq., Commissioner, Tax Exempt and Government Entities | Internal Revenue Service

Edward Killen is the Commissioner of the Tax Exempt & Government Entities (TE/GE) business operating division of the Internal Revenue Service, where he is responsible for administering the tax laws governing employee retirement plans, tax-exempt organizations, tax-exempt bonds, Indian tribal governments, and federal, state, and local governments. He was selected as TE/GE Commissioner following the retirement of Commissioner Sunita Lough, having served in the role since September 30, 2022. Prior to assuming the TE/GE Deputy Commissioner role in October 2019, he served as the IRS Chief Privacy Officer, leading Privacy, Governmental Liaison and Disclosure (PGLD), where he managed a multifaceted privacy program and ensured compliance with the Privacy Act, the Freedom of Information Act, the Federal Records Act, and Internal Revenue Code 6103. In 2025, he was promoted to the IRS’s acting chief taxpayer compliance officer, a role in which he enforces tax administration policy while overseeing taxpayer service, compliance efforts, and criminal investigations.

• Education & Credentials

Edward earned a Master’s Certificate in project management from the George Washington University School of Business. He holds a Certified Information Privacy Professional, Government (CIPP/G) credential, a Bachelor of Arts degree in political science from Valdosta State University, and a Juris Doctor degree from the University of Florida Levin College of Law. He is a member of the Florida Bar Association and the United States Tax Court.

• Recognition & Leadership

Edward was appointed a member of the Internal Revenue Service Legal Division Performance Review Board, serving in that capacity in his role as Deputy Division Commissioner, Tax Exempt and Government Entities. His leadership is further reflected in his progressive executive roles within the IRS, including TE/GE Commissioner, IRS Chief Privacy Officer, and Director of Governmental Liaison, Disclosure and Safeguards within PGLD. He began his federal service career as a Presidential Management Fellow.

• Professional Involvement

Edward is a member of the Florida Bar Association and the United States Tax Court, and he served as a member of the IRS Legal Division Performance Review Board.

• Experience

Edward’s career has been built largely within the Internal Revenue Service across a range of executive and leadership positions. He has served as Commissioner of TE/GE since September 30, 2022, succeeding Sunita Lough, and in 2025 was promoted to acting chief taxpayer compliance officer, overseeing taxpayer service, compliance efforts, and criminal investigations. He assumed the TE/GE Deputy Commissioner role in October 2019. Before that, he served as IRS Chief Privacy Officer leading PGLD, where he represented the IRS’s interests across privacy compliance, records management, information protection, disclosure, data sharing, and combating identity theft. He previously served as Director, Governmental Liaison, Disclosure and Safeguards within PGLD, providing oversight of policies and procedures regarding access to and disclosures of Federal Tax Information (FTI) under IRC Section 6103 — encompassing IRS compliance with FOIA, data exchanges with federal, state, and local government agencies, and safeguarding FTI in the custody of exchange partners. He also served as Director of the Office of Safeguards within PGLD and as Senior Advisor to the IRS Deputy Commissioner of Operations Support, providing authoritative counsel and advice. Earlier, he was on a long-term assignment to the IRS Services and Enforcement Affordable Care Act Program Office, where he played a key role in the initial scoping of the IRS’s responsibilities under the act, and before that served as Chief of the Enterprise Continuous Monitoring Branch of the W&I Security Program Management Office. He began his federal service career as a Presidential Management Fellow, with an initial appointment to the Social Security Administration Office of Hearings and Appeals. In 2003, he transferred his appointment and joined the IRS as a policy analyst within W&I Strategy and Finance, where he led the development of the W&I business plan and was part of a small group that stood up the initial Identity Theft program office within the IRS. His numerous detail assignments across the IRS include work within IRS Counsel’s office, the 2008 Economic Stimulus Program, and the Internet Strategy team.

Jennifer Breen, Esq., Partner | Morgan Lewis & Bockius

Jennifer Breen is a Partner at Morgan Lewis who represents domestic and multinational businesses, large partnerships, high-net-worth individuals, and family offices on tax controversy and Internal Revenue Service (IRS) administrative matters. She also counsels professional services firms, investment fund managers, and private equity firms on partnership tax issues. With decades of experience spanning government service, a “Big Four” public accounting firm, and in-house as the director of tax controversy for a large multinational corporation, Jennifer offers a rare perspective and an invaluable ability to see tax issues from multiple vantage points. Her proven skills and extensive background include all aspects of tax controversy and litigation, including managing IRS audits, filing and presenting protests in IRS Appeals, and ultimately litigating cases before the United States Tax Court and other federal courts. Drawing on her experience as an attorney with the IRS Office of Chief Counsel’s National Office, she marries substantive tax knowledge with strong relationships at the IRS and firsthand insights into navigating issues, seeking guidance, and understanding administrative processes and federal rulemaking, often seeking to resolve issues at the earliest stage possible through procedural techniques including pre-filing agreements, private letter ruling requests, requests for technical advice, and other informal methods.

• Education & Credentials

Jennifer earned her J.D. from the University of Houston Law Center in 2001 and a B.A. in Political Science and Government from the University of Texas at Austin in 1998. She is admitted to practice in the District of Columbia and Texas, and before the U.S. Court of Appeals for the First Circuit, the U.S. Court of Appeals for the Federal Circuit, the U.S. Court of Federal Claims, and the U.S. Tax Court.

• Recognition & Leadership

Jennifer is listed in Lawdragon’s 500 Leading Global Tax Lawyers for Washington, D.C., Tax, Controversy, Litigation (2025). She is recognized as Highly Regarded for Tax Controversy in the District of Columbia and as a Women in Tax Leader for Tax Controversy in the District of Columbia in International Tax Review’s World Tax Guide (2025, 2026). She is ranked for Tax: Private Client (Nationwide) in the Chambers High Net Worth Guide (2024, 2025) and for Tax in the District of Columbia in Chambers USA (2022–2025), having previously been recognized as Up-and-Coming for Tax in the District of Columbia (2020, 2021). She is recommended for Tax: US taxes: contentious in The Legal 500 US (2019, 2020) and was recommended more broadly in The Legal 500 US (2016). She is listed in The Best Lawyers in America for Tax Law in Washington, D.C. (2022–2026) and recognized by Washingtonian Magazine for Tax (2020). She was named among the Emerging Women Leaders in Private Practice by DCA Live (2019) and was a member of Law360’s Practice Group of the Year for Tax (2017). She received the IRS Special Act Award (2002–2005).

• Professional Involvement

Jennifer is a Fellow of the American College of Tax Counsel and a member of the J. Edgar Murdock Inn of Court. Within the American Bar Association’s Section of Taxation, she serves as a Council Director and previously served as Chair of Administrative Practice (2017–2018). She is a Director and Treasurer of the Washington DC Center for Public Interest Tax Law, a nonprofit tax clinic providing pro bono legal services to taxpayers across the United States, where she oversees clinic operations including regular attendance at United States Tax Court calendar calls and the delivery of pro bono legal representation to low-income taxpayers.

• Experience

Jennifer’s career spans government, public accounting, in-house, and private practice. She served as an attorney with the IRS Office of Chief Counsel’s National Office. Prior to joining Morgan Lewis, she distinguished herself as a trusted in-house advisor for Mattel, an American multinational toy manufacturing and entertainment company, where she gained a keen understanding of all aspects of tax compliance and controversy from an in-house perspective. In that capacity, she was responsible for all matters involving US federal income tax and foreign tax controversies, as well as those involving state and local corporate and business tax, sales and use tax, and escheat and unclaimed property audits, and she managed the company’s global reportable transaction compliance and compliance under the Foreign Account Tax Compliance Act. While with PwC, she represented major corporations, partnerships, S corporations, and individuals in resolving domestic and international controversy issues, counseled clients on risk management matters, and routinely advised on filing and compliance issues as well as other issues arising with accounting, audit, and internal controls. She also routinely advises clients on filing and compliance matters, voluntary disclosures, interest issues, penalty abatement actions, IRS requests and summonses, enforcement proceedings, and joint defense agreements.

Diana L. Erbsen, Esq., Partner | DLA Piper

Diana L. Erbsen is a Partner at DLA Piper, based in New York, with 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, she was appointed to the position of Deputy Assistant Attorney General for Appellate and Review for the Tax Division of the US Department of Justice (DOJ) by President Obama, and following the end of the administration on January 20, 2017, she returned to DLA Piper as a partner. Since returning, she has resumed representing public and privately held corporations, as well as partnerships, estates, and individuals, in all aspects of tax disputes, concentrating 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.

• Education & Credentials

Diana earned an LL.M. from New York University, a J.D. from Northeastern University, and a B.A., cum laude, from Amherst College, where she held the Charles Hamilton Houston Fellowship for Scholarship & Citizenship and the John Woodruff Simpson Fellowship for the Study of Law. She is admitted to the bar in Connecticut, the District of Columbia, and New York. Her court admissions include the Supreme Court of the United States, the United States Tax Court, the United States Court of Appeals for the Federal Circuit, the United States Court of Appeals for the Second Circuit, the United States Court of Federal Claims, the United States District Court for the Southern District of New York, and the United States District Court for the Eastern District of New York. In April 2024, she was awarded a Certification of Successful Completion of Mediation Skills Training by Quinnipiac University Law School’s Center on Dispute Resolution.

• Recognition & Leadership

Diana is ranked by Chambers USA in Band 3 for Nationwide Tax: Controversy (2021–2025), having previously been ranked Band 4 (2020), and was ranked Band 1 for Nationwide Tax: Private Client, High Net Worth (2024). She is recognized by The Legal 500 United States as a Leading Partner for US Taxes: Contentious (2024–2025) and was Recommended in that category (2018–2023). In January 2017, she was recognized by IRS Chief Counsel William Wilkins with the Chief Counsel Award for her leadership and oversight of the Appellate Section of the Tax Division. She was appointed to the ABA Tax Section’s Appointments to the Tax Court Committee for a five-year term (2024–2029), serves on the American College of Tax Counsel Board of Regents as 2nd Circuit Regent, and was a member of the Law360 Tax Authority Federal 2024 Editorial Board.

• Professional Involvement

In 2020, Diana served as Chair of the IRS Advisory Council (IRSAC), which advises the IRS Commissioner on tax administration issues. Her IRSAC service, along with her roles in the leadership of the American Bar Association Tax Section and the American College of Tax Counsel (for which she currently serves as the 2nd Circuit Regent), 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. She has been a member of the J. Edgar Murdock Inn of Court since 2015. She is an active speaker and panelist, having presented at venues including the NYU School of Professional Studies Tax Controversy Forum, the ABA Annual National Institute on Criminal Tax Fraud & Tax Controversy, the DC Bar Tax Conference, and the International Tax Review’s Annual Women in Tax Forum, and is frequently quoted in publications such as Tax Notes, Law360, Forbes, and The Wall Street Journal.

• Experience

Diana served as Deputy Assistant Attorney General for Appellate and Review in the Tax Division of the US Department of Justice. In her capacity as a Presidential appointee to the DOJ’s Tax Division, she oversaw its largest section, the Appellate Section (responsible for all appellate litigation, including to the Supreme Court), the Office of Review (responsible for civil settlements), and the Financial Litigation Unit (tasked with collecting judgments secured by the Trial Sections of the Tax Division). 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. Earlier in her career, she served as AttorneyAdviser to the Hon. Robert Armen, Jr. of the US Tax Court. Among the specific, highly skilled areas in which she has had substantial experience are representing clients in connection with subpoenas issued by the Senate Permanent Subcommittee on Investigations; representing clients in art-related matters (including estate and gift tax, auction house guarantees, sales tax, and alleged fraudulent transfers); representing accounting firms and accountants in matters involving their ethical obligations (including pursuant to Circular 230) and their obligations under federal and state tax laws (including relating to material advisor rules, preparer penalties, and disclosure of taxpayer information); and assisting individual and institutional clients in becoming compliant with US tax laws (including with regard to undisclosed foreign financial accounts and assets).

Hon. Patrick J. Urda, Chief Judge | United States Tax Court

Patrick J. Urda is the Chief Judge of the United States Tax Court. Born in Indiana, he was appointed by President Trump as Judge of the United States Tax Court and sworn in on September 27, 2018, for a term ending September 26, 2033. He was elected Chief Judge for a two-year term effective June 1, 2025.

• Education & Credentials

Judge Urda received a Bachelor of Arts degree, summa cum laude, from the University of Notre Dame and a Juris Doctor from Harvard Law School.

• Recognition & Leadership

His Bachelor of Arts was conferred summa cum laude from the University of Notre Dame. His leadership is reflected in his election as Chief Judge of the United States Tax Court, effective June 1, 2025, for a two-year term.

• Professional Involvement

Judge Urda formerly served as an Adjunct Professor of Law at American University Washington College of Law.

• Experience

Prior to his appointment to the Court, Judge Urda practiced law with McDermott Will & Emery and with Maciorowski, Sackmann & Ulrich. He served as a Law Clerk to Judge Daniel A. Manion of the U.S. Court of Appeals for the Seventh Circuit and held several positions with the U.S. Department of Justice’s Tax Division, including details as Counsel to the Deputy Assistant Attorney General for Appellate and Review and to the Criminal Division’s Office of Overseas Prosecutorial Development Assistance and Training. He was appointed to the United States Tax Court and sworn in on September 27, 2018, for a term ending September 26, 2033, and was elected Chief Judge effective June 1, 2025.

Kenneth J. Kies, Esq., Acting Chief Counsel, Internal Revenue Service; Assistant Secretary, Tax Policy | US Department of the Treasury

Kenneth J. Kies serves as Assistant Secretary of the U.S. Department of the Treasury for Tax Policy, the senior advisor to the Secretary of the Treasury responsible for analyzing, developing, and implementing federal tax policies and programs. Nominated by President Trump in January 2025, he was confirmed by the United States Senate on June 26, 2025, by a vote of 53-45, and reports directly to Treasury Secretary Scott Bessent. He has devoted his professional career to federal tax policy and law in both the public and private sectors, having worked on virtually every aspect of the tax code. He stepped down as Managing Director of the Federal Policy Group, LLC on March 14, 2025, a position he had held since February 2002.

• Education & Credentials

Kenneth Kies attended college at Ohio University in Athens, Ohio. He began the practice of law in 1977 in Cleveland after graduating from the Ohio State University College of Law.

• Recognition & Leadership

Kenneth Kies’s leadership is reflected in his senior governmental and professional roles, including Assistant Secretary of the Treasury for Tax Policy, Chief of Staff of the Joint Committee on Taxation, and Chief Republican Tax Counsel to the House Committee on Ways and Means. In 1997, he initiated a yearlong project to analyze the potential for macroeconomic estimates of major tax policy changes, resulting in the publication of the Joint Committee on Taxation Tax Modeling Project in December 1997 — at the time the most significant project of its kind and the beginning of an estimating capability that continues at the Joint Committee to this day. He served as Co-Chair, with Michael Boskin (former Chair of the Council of Economic Advisers for President George H.W. Bush), of the 1996 Ways and Means Retreat on Tax Reform under Chairman Bill Archer.

• Professional Involvement

After leaving the Joint Committee in January 1998, Kenneth Kies continued to serve at the request of Speaker Newt Gingrich and Chairman Archer in an effort to negotiate a permanent long-term solution to the solvency of the Social Security system with the Clinton Administration, in particular with Gene Sperling and Larry Summers. That effort culminated in his participation in the December 1998 White House Conference on Social Security, alongside fellow panelists Martin Feldstein (former Chair of the Council of Economic Advisers under President Ronald Reagan) and Robert Reischauer (former head of CBO); the project is recounted in a book on the history of the Social Security system entitled The People’s Pension.

• Experience

Kenneth Kies’s career spans congressional staff service, private legal practice, public accounting, and taxpolicy consulting. He began the practice of law in 1977 as a tax associate with BakerHostetler in Cleveland. From 1981 until 1987, he served as Chief Republican Tax Counsel to the House Committee on Ways and Means, where he was actively involved in the development of all tax legislation, including the Economic Recovery Tax Act of 1981 and the Tax Reform Act of 1986. He subsequently served as the firmwide Chair of the Tax Practice for BakerHostetler. He served as Chief of Staff of the Joint Committee on Taxation from 1995 until 1998, overseeing development of major tax legislation including the Taxpayer Relief Act of 1997 (the first net tax cut since the 1981 Act), the Small Business Job Protection Act of 1996, and the Health Insurance Portability and Accountability Act of 1996, and helping design and negotiate the IRS Restructuring Act of 1998 with Congressman Rob Portman, Senator Ben Cardin, and Secretary of the Treasury Robert Rubin. He then served as Co-Managing Partner of the Washington National Tax Services office of PricewaterhouseCoopers LLP. From February 2002 until March 14, 2025, he was Managing Director of the Federal Policy Group, LLC, a private-sector firm providing advocacy, strategic consulting, and technical advice on tax policy matters before Congress, the Treasury Department, and the Internal Revenue Service. He was confirmed as Assistant Secretary of the Treasury for Tax Policy in June 2025.

Christopher M. Ferguson, Esq., Partner | Kostelanetz

Christopher M. Ferguson is a Partner at Kostelanetz LLP, based in New York City, with over two decades of experience as a litigator. He concentrates his practice on white-collar criminal defense as well as civil and criminal tax controversies and other regulatory enforcement matters and also has extensive experience handling complex civil litigation and internal investigations. Chris represents clients in both federal and state courts, as well as before governmental agencies and other regulatory bodies, including the U.S. Department of Justice, the Internal Revenue Service, the Securities and Exchange Commission, FINRA, the New York Attorney General’s Office, the U.S. Department of Labor, the New York City Department of Investigations, and the Manhattan District Attorney’s Office. He has defended clients in federal and state investigations and prosecutions involving allegations of tax fraud, securities fraud, criminal anti-trust violations (bid rigging and price fixing, including in the foreign exchange market), Bank Secrecy Act violations, mail and wire fraud, CARES Act fraud, prevailing wage fraud, theft of government services, fraud related to state and local Minority and Women Business Enterprise (MWBE) programs, and other violations of federal and state law. He also conducts internal investigations for institutional clients whose officers or employees have been suspected or accused of wrongdoing.

• Education & Credentials

Chris received his B.A., magna cum laude, from Boston College in 1994, and his J.D. from New York University School of Law in 1999. He is admitted to practice in New York State (2000), the U.S. District Court for the Southern District of New York (2001), and the U.S. District Court for the Eastern District of New York (2001).

• Recognition & Leadership

Chris is recognized in Super Lawyers for Criminal Defense: White-Collar in New York, and in Best Lawyers for Commercial Litigation and for Litigation and Controversy – Tax in New York. The Legal 500 describes him as a “key lawyer” at the Firm, and International Tax Review/World Tax describes him as “highly regarded” in the area of tax controversy. He is the former Secretary of the Criminal Law Committee of the New York City Bar Association.

• Professional Involvement

Chris is a member of the New York Council of Defense Lawyers and is the former Secretary of the Criminal Law Committee of the New York City Bar Association, having been a member of that committee since 2010. He publishes and speaks extensively in the areas of white-collar crime and civil and criminal tax controversies, with recent speaking engagements including “Tax Enforcement Trends: What’s Hot and What’s Not” (November 2024) and “Employee Retention Credit Update: Current Knowledge and Future Projections” (July 2024), and recent publications including “Defending a Pandemic Fraud Prosecution” (September 2025) and “Demystifying DeFi: Tax Compliance for Individuals Engaging In Decentralized Finance (DeFi) Transactions” (July 2025).

• Experience

In his civil practice, Chris has represented both plaintiffs and defendants in a variety of complex commercial and regulatory matters, including wage and hour class actions, Department of Labor investigations, tax shelter litigations, government procurement matters, and commercial litigations involving breach of contract, breach of fiduciary duty, fraudulent conveyances, civil fraud, civil RICO, civil forfeiture, and similar claims. Prior to joining Kostelanetz LLP, he served as a law clerk to the Honorable Jay C. Waldman of the United States District Court for the Eastern District of Pennsylvania, and was associated with the law firm of Dewey Ballantine, LLP, where he practiced in the areas of complex commercial, antitrust, and bankruptcy litigation. Among his representative matters, he has persuaded prosecutors not to charge clients and obtained non-prosecution agreements in numerous criminal tax and white-collar investigations, successfully persuaded the Office of IRS Appeals to fully abate fraud penalties assessed against a hedge fund manager, represented multiple taxpayers in tax shelter litigations in federal district courts and tax court, and conducted internal investigations for not-for-profit, quasi-governmental, and public-company clients involving suspected embezzlement, bribery, wage violations, and regulatory misconduct.

Megan E. Marlin, Esq., Principal | PwC

Megan E. Marlin is a Principal at PricewaterhouseCoopers LLP (PwC) in Washington, DC, specializing in compensation and benefits, with a practice focused on employment tax consulting and compliance within the firm’s Workforce Transformation group. She advises for-profit and tax-exempt employers on worker classification, fringe benefits, global mobility, remote and hybrid work arrangements, compensation arrangements, legal entity simplification, payroll transformation, post-deal integration, and federal and state payroll tax compliance. She also represents clients before the IRS and state taxing authorities to negotiate settlement agreements, manage penalty abatement requests, and lead audit and appeals defense. Prior to rejoining PwC, Megan served as Legislation Counsel for the nonpartisan Joint Committee on Taxation, where she advised Members of Congress, the House Committee on Ways and Means, and the Senate Finance Committee in the areas of employment tax, executive compensation, retirement plans, and healthcare.

• Education & Credentials

Megan graduated from the College of William & Mary in 2006 with a B.A. in International Relations. She subsequently received a J.D., cum laude, from Suffolk University Law School and an LL.M. in Taxation, specializing in Employee Benefits, from Georgetown University Law Center.

• Recognition & Leadership

Megan is the US Domestic leader for the Global Employment Tax network at PwC and is the former chair of the Employment Taxes committee of the American Bar Association. At William & Mary, she was a captain of the Division I volleyball team, a representative on the Student Athletic Advisory Council, and co-founder of the William & Mary chapter of the pre-law fraternity Phi Alpha Delta.

• Professional Involvement

Megan serves as a member of the William & Mary Washington Center Advisory Board. She is a frequent panelist for the American Bar Association, the Maryland State Bar Association, the Tax Executive Institute, and the Practicing Law Institute, and is the former chair of the ABA’s Employment Taxes committee.

• Experience

Megan is a Principal at PwC, where she advises employers on corporate restructuring and payroll transformation, global mobility, fringe benefits, equity compensation, worker classification, tax controversy, and the federal and state payroll tax compliance function. She has significant experience counseling employers on travel expense reimbursements, fringe benefits, worker classification, equity compensation, third-party payroll arrangements, U.S. employment taxes for inbound and outbound employees, and the employment tax consequences of change-of-control events, and she represents taxpayers before the IRS to negotiate settlement agreements and navigate IRS examinations and appeals. Prior to rejoining PwC, she served as Legislation Counsel with the Joint Committee on Taxation, where she assisted congressional tax-writing committees and Members of Congress with the development and analysis of legislative proposals. Earlier in her career, before joining PwC, she was an attorney specializing in tax controversy and employment taxes at a mid-sized law firm in Baltimore, Maryland, where she assisted companies with the negotiation of installment agreements and offers in compromise with the IRS and advised clients on general tax matters.

Daniel Graham Strickland, Esq., Partner | Holland & Knight

Daniel Graham Strickland is a Partner and tax attorney in Holland & Knight’s Washington, D.C., office. He focuses his practice in the area of federal tax controversy, representing taxpayers in all types of tax controversy matters, and also focuses on the renewable energy sector, advising clients on energy tax credits and incentives from conception to litigation. In the context of tax controversy, he guides clients through IRS audits, prepares administrative claims and protests of IRS actions, and litigates tax and tax-related cases throughout the United States, with experience covering a wide range of procedural and complex tax issues, including valuation, foreign and energy tax credits, classification of investment as debt or equity, judicial substance doctrines, and penalty defenses. In the energy sector, he advises clients on tax credits, such as investment tax credits (ITCs), production tax credits (PTCs), carbon capture, hydrogen, electric vehicle, fuels, and other energy tax credits, including through the Inflation Reduction Act (IRA) and on the impact of fuels, oil spill, and Superfund excise taxes to current and anticipated business operations.

• Education & Credentials

Daniel earned his LL.M., with distinction, from Georgetown University Law Center; his J.D., magna cum laude, from the Charleston School of Law; and his B.S. from the University of South Carolina. He is admitted to the bar in the District of Columbia. His court admissions include the U.S. Supreme Court, the U.S. Tax Court, the U.S. District Court for the District of Columbia, and the U.S. Courts of Appeals for the Second, Fourth, Fifth, Ninth, and Eleventh Circuits. While in law school, he served as the research editor for the Charleston Law Review.

• Recognition & Leadership

Daniel was named a John S. Nolan Fellow by the American Bar Association (ABA) Section of Taxation for 2024-2025. He is recognized in The Best Lawyers in America guide as “Ones to Watch” for Washington, D.C. Litigation and Controversy, Tax (2021-2025) and for Washington, D.C. Energy Law and Tax Law (2024, 2025). His leadership roles include serving as Section Chair of the Federal Bar Association’s Section on Taxation (2022-2023) and as Vice Chair of the ABA Section of Taxation’s Energy & Environmental Taxes Committee (2022-Present).

• Professional Involvement

Daniel is active in several professional organizations. Within the Federal Bar Association (FBA) Section on Taxation, he served as Section Chair (2022-2023), is Past Co-Chair of the Tax Practice and Procedure Committee and has been a Steering Committee Member since 2017. Within the American Bar Association (ABA) Section of Taxation, he serves as Vice Chair of the Energy & Environmental Taxes Committee (2022Present) and previously served as Technology Liaison to the Court Practice and Procedure Committee (2021-2022). He is also a member of the D.C. Bar Association’s Taxation Community and is Past Chair of its New Tax Practitioner Subcommittee. He represents clients in the traditional and renewable energy sectors in legislative and regulatory efforts, including in obtaining public and private guidance from the U.S. Department of the Treasury and the IRS.

• Experience

Prior to joining Holland & Knight, Daniel was an attorney for a global law firm in its Washington, D.C., office. Previously, he served as a law clerk at the U.S. Tax Court for the Honorable Albert G. Lauber, the Honorable Elizabeth Crewson Paris, and the Honorable Michael B. Thornton. He represents clients in tax controversy matters at the administrative, trial court, and appellate levels, guiding them through IRS audits, preparing administrative claims and protests of IRS actions, and litigating tax and tax-related cases throughout the United States. In the energy sector, his work spans advising clients on a broad range of energy tax credits and incentives and on the impact of fuels, oil spill, and Superfund excise taxes, as well as representing clients in legislative and regulatory efforts before the U.S. Department of the Treasury and the IRS.

Leila D. Carney, Esq., Member | Caplin & Drysdale, Chartered

Leila D. Carney is a Member at Caplin & Drysdale, based in Washington, D.C., and a seasoned tax lawyer with a focus on resolving disputes with the IRS. Her core practice involves providing a surgical defense to IRS audits, assessments, and penalties, including litigation in the Court of Appeals for the D.C. Circuit, the U.S. Tax Court, Federal District Court, and the D.C. Circuit Court against the IRS and the Department of Justice. She is adept at handling multifaceted issues involving global business and investing structures for individuals, corporate clients, and complex trusts, and has handled sensitive IRS exams, administrative appeals, criminal matters, Circular 230 disciplinary proceedings, represented subpoenaed witnesses, and submitted ruling requests and comment letters on proposed regulations. She has practiced in the Tax Disputes & Tax Litigation Group since first joining Caplin & Drysdale’s Washington, D.C. office in 2004, and also provides her tax, litigation, and federal law expertise to the firm’s Complex Litigation, Criminal Tax & White Collar Defense, Private Client, and Political Law Practices.

• Education & Credentials

Leila earned her J.D. from the University of Virginia School of Law in 2004 and her B.A. from The College of William & Mary in 2001. She is admitted to practice in the District of Columbia and Virginia, and before the U.S. Court of Appeals for the D.C. Circuit, the U.S. Tax Court, the U.S. District Court for the Eastern District of Virginia, and the D.C. Circuit Court.

• Recognition & Leadership

Leila serves on the Tax Notes Federal Advisory Board, shaping content for Tax Analysts, a leading publisher on tax law and policy. She was elected a Member of Caplin & Drysdale in October 2023. Her thought leadership is reflected in her frequent commentary in outlets including Bloomberg Law, Tax Notes, Law360, Financial Planning, Accounting Today, MarketWatch, The Hill, and others, on matters such as Moore v. United States, the Chevron decision, the Corporate Transparency Act, and regulatory authority in tax legislation.

• Professional Involvement

Leila is a Member of the Tax Notes Federal Advisory Board, the American Bar Association’s Section of Taxation, and the District of Columbia Bar. Within the ABA Tax Section, she has led the Administrative Practice Committee on the IRS LB&I Puerto Rico Campaign (August 2024). She is an active speaker and author, with engagements including the NYU Tax Controversy Forum (exploring the Employee Retention Credit, June 2026), and publications appearing in the Pittsburgh Tax Review, Practical Tax Strategies (Thomson Reuters), Procedurally Taxing, and the firm’s Tax and International Tax Alerts on topics such as the Corporate Transparency Act, Puerto Rico residency audits, conservation easements, and refund claims.

• Experience

Throughout her career, Leila has zealously won an appeal to the D.C. Circuit Court of Appeals, converting a Tax Court loss into a win; litigated cases involving foreign-source income, captive insurance, conservation easements, and IRS third-party summonses; defended Puerto Rico residency and sourcing in IRS campaign audits; navigated the Congressional Joint Committee on Taxation large tax refund review process; defended a gift tax return examination involving a high-net-worth trust structure; sought full abatement of civil penalties related to foreign trust reporting, return preparer penalties, and appraiser penalties; sought full allowance of large deductions in IRS “hobby loss,” “cost segregation,” and “real estate professional” examinations, and a refund of Net Investment Income Tax (NIIT); assisted victims of criminal tax return preparers in providing testimony and correcting returns; coordinated reinstatement of an inadvertent S-corp termination; sought “9100” relief for missed “check the box” elections; and advised on presidential ballot access law and procedure. She has represented clients in sensitive audits with a risk of allegations of tax fraud or securities fraud, assisted clients responding to subpoenas for civil and criminal proceedings and those under investigation, and protested civil penalties including those specific to foreign bank accounts, trusts, gifts, preparers, promoters, and appraisers. She has represented clients on voluntary disclosures and collection matters such as offers-in-compromise, lien releases, installment agreements, decertifying passports, and innocent spouse petitions; assisted with state tax aspects such as California Franchise Tax Board exams, resolution programs, and collection activities; and is experienced in obtaining and defending tax-exempt status for public and private charities as well as trade associations. She has also advised clients on creating business practices that comply with changing regulatory regimes, including those governing taxpayer consent to disclosure of tax return information, foreign bank account reporting (FBAR), and nonqualified deferred compensation plans, and has assisted clients in submitting comments on proposed regulations.

Eric Hylton, National Director | alliant

Eric Hylton is a National Director (National Director of Compliance) at alliantgroup and the former IRS Commissioner of the Small Business/SelfEmployed (SB/SE) Division, a position to which he was appointed in September 2019. He spent approximately 30 years at the Internal Revenue Service, where he held several prominent positions, including serving as Deputy Chief of the Criminal Investigation (CI) Division and as CI’s head of International Operations. As National Director at alliantgroup, he employs his years of experience at the IRS to assist the firm’s clients, serving as an ambassador for U.S. small and medium-sized businesses (SMBs) and helping others become tax compliant.

• Education & Credentials

Eric attended Morehouse College.

• Recognition & Leadership

Eric is the former chair of the Organization for Economic Cooperation and Development (OECD) Task Force for Tax Crimes and Other Financial Crimes. As Chair, he led a multilateral commission of 40 international criminal tax organizations to develop methodologies and typologies on emerging global criminal tax and financial crimes threats — work that resulted in significant legislative changes, billions in revenue, and the establishment of joint international investigative teams. His leadership is further reflected in his senior IRS roles, including Commissioner of the SB/SE Division, Deputy Chief of the Criminal Investigation Division, and head of CI’s International Operations.

• Professional Involvement

In his role at alliantgroup, Eric serves as an ambassador for U.S. small and medium-sized businesses and assists clients in becoming tax compliant. He also served as the former chair of the OECD Task Force for Tax Crimes and Other Financial Crimes, and has served as Director of Investigations for Zerbe, Miller, Fingeret, Frank & Jadav LP (ZMF Law), advising clients on criminal tax investigations, tax controversy matters, internal investigations, cryptocurrency, and whistleblower claims.

• Experience

Eric’s career has spanned approximately 30 years of senior leadership at the IRS, subsequent private-sector roles, and his current position at alliantgroup. Within the IRS, he held positions including Commissioner of the Small Business/Self-Employed Division (appointed September 2019), Deputy Chief of the Criminal Investigation Division, Executive Director / head of CI’s International Operations, and Director of CI’s Narcotics and Counterterrorism Office. Among his select career accomplishments, in civil investigation he directed the IRS’s Audit and Collection tax operations with a $2.2 billion yearly budget and 20,000 nationwide employees, with oversight for 800,000 audits and billions of tax dollars assessed and collected. In criminal investigation, he oversaw the sixth-largest U.S. federal law enforcement agency, with a worldwide staff of approximately 3,000 employees that resulted in over 6,000 investigations recommended for prosecution, leading to thousands of individuals convicted and sentenced. In fraud investigation, he revolutionized the IRS’s National Fraud Program — establishing emerging threat teams, revamping organizational structure, revising metrics, and streamlining processes that resulted in multimillion-dollar fraud schemes being referred for criminal purposes. In the area of international partnership, he led a multilateral commission of 40 international criminal tax organizations to establish global methodologies on emerging financial fraud threats, resulting in significant legislative changes, billions in revenue, and the establishment of joint international investigative teams. He later served as Director of Investigations for ZMF Law before his role as National Director at alliantgroup.

David W. Foster, Esq., Partner | Kirkland & Ellis

David W. Foster is a partner in the Tax Disputes 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’s Global High Wealth initiative. His practice covers a diverse range of tax issues, including BBA partnership audit and litigation procedures, energy tax credits, international tax and transfer pricing, challenges to tax-exempt status, taxation of financial products, estate and gift taxes, deferred compensation, voluntary disclosures, and criminal tax. A former Supreme Court clerk for Justice Kennedy, David has prepared briefs and argued before many of the federal courts of appeals. He lectures regularly to in-house tax departments and professional associations.

• Education & Credentials

David earned his J.D. from Harvard Law School in 2005, where he served as Supreme Court Chair of the Harvard Law Review, and his A.B. from Harvard University in 2000. He is admitted in the District of Columbia and Massachusetts, and before the Supreme Court of the United States; the U.S. Court of Appeals for the Armed Forces; the U.S. Courts of Appeals for the D.C., Second, Fifth, Sixth, Seventh, Eighth, Ninth, Tenth, Eleventh, and Federal Circuits; the U.S. District Court for the District of Columbia; the U.S. Court of Federal Claims; the U.S. Court of International Trade; and the United States Tax Court.

• Recognition & Leadership

David is a fellow of the American College of Tax Counsel and the American Bar Foundation. He has repeatedly been ranked in Chambers USA (Tax, 2020–2025), Chambers High Net Worth, The Best Lawyers in America (2020–2026), and The Legal 500 United States, where in the 2024 edition he was listed as a “Leading Lawyer” for US Taxes: Contentious (and recognized for International Tax and U.S. Taxes: NonContentious). He was previously recognized as one of Washington, D.C.’s Trending 40 Lawyers Under 40 by Legal Bisnow and has been included in Washingtonian’s Top Lawyers list since 2018.

• Professional Involvement

David served as chair of the D.C. Bar’s Tax Audits and Litigation Committee and as co-chair of the ABA Tax Section’s Privileges Subcommittee of the Civil and Criminal Tax Penalties Committee. He lectures regularly to in-house tax departments and professional associations and is a prolific speaker before organizations including the NYU Tax Controversy Forum, the Tax Executives Institute, the ABA Section of Taxation, the Federal Bar Association, the University of Chicago Law School’s Annual Federal Tax Conference, the Heckerling Institute on Estate Planning, and the D.C. Bar Tax Conference, on topics such as the Administrative Procedure Act and the IRS, the aftermath of Loper Bright and the end of Chevron deference, the economic substance doctrine, partnership audit enforcement, and privilege issues. He authored the Chambers Global Practice Guide: Tax Controversy (Law and Practice – USA), 2019.

• Experience

Many of David’s most significant representations involve proceedings before the IRS and DOJ where the taxpayer’s privacy is closely guarded, including representing private equity firms and hedge funds and their individual owners in IRS examinations, before IRS Appeals, and in Tax Court trial testimony (with disputes spanning taxation of financial products, distressed debt, and retirement accounts, valuation issues, existence of a U.S. trade or business, charitable contribution deductions, information and FBAR reporting, and cross-border withholding); corporations regarding the deductibility of litigation-settlement payments; prominent individuals in Global High Wealth examinations with more than $1 billion of proposed deficiencies; and individuals in offshore voluntary disclosures and grand jury investigations. Prior to joining Kirkland, his representations included Hewitt v. Commissioner, 21 F.4th 1336 (11th Cir. 2021), an appellate victory striking down a Treasury regulation as arbitrary and capricious under the APA; Cross Refined Coal, LLC v. Commissioner (Tax Court 2019), aff’d, 45 F.4th 150 (D.C. Cir. 2022), trial and appellate victories holding that a clean energy tax credit partnership was bona fide; representation of a hedge fund in what The Wall Street Journal described as one of the largest tax settlements in history; representation of prominent estates in some of the largest Tax Court gift and estate tax cases in history, with favorable resolutions of asserted deficiencies in excess of $2.8 billion and $500 million; a jury acquittal of an attorney on tax evasion charges; the successful defense of an IRS attempt to revoke a nonprofit’s tax-exempt status; Ingersoll Rand Co. v. Commissioner; and Massachusetts Mutual Life Insurance Co. v. United States, 782 F.3d 1354 (Fed. Cir. 2015), affirming the timing of an insurance company’s deduction of nearly $250 million in policyholder dividend payments. He also represented five former IRS commissioners in a D.C. Circuit amicus brief in Loving v. IRS supporting licensing standards for tax return preparers, and the American College of Tax Counsel in amicus briefs in the Tax Court and the Supreme Court. David served as a law clerk to the Honorable Anthony M. Kennedy of the Supreme Court of the United States (2006–2007) and to the Honorable Alex Kozinski of the U.S. Court of Appeals for the Ninth Circuit (2005–2006), and he was previously a partner at Skadden, Arps, Slate, Meagher & Flom LLP.

Nikki S. Bossert, Esq., Senior Technician Reviewer | Office of the Associate Chief Counsel (Procedure & Administration), Internal Revenue Service

Nikki S. Bossert is a Senior Technician Reviewer at the IRS Office of Chief Counsel, Procedure & Administration, Branch 6, working in the Richmond, Virginia office. Ms. Bossert works primarily on matters involving the economic substance doctrine, the BBA partnership audit rules, and FOIA. The IRS Office of Chief Counsel serves as the chief legal advisor to the IRS Commissioner on the interpretation, administration, and enforcement of the Internal Revenue laws, providing legal guidance and interpretive advice to the IRS, Treasury, and taxpayers.

• Education & Credentials

Ms. Bossert graduated, cum laude, from Quinnipiac University School of Law in 2015.

• Professional Involvement

Ms. Bossert is the author and co-author of published tax articles. Her writing has addressed federal filing requirements for amending partnership returns under the Bipartisan Budget Act (BBA) of 2015 and the corresponding state-level effects across multiple states, as well as state taxing-authority issues arising after the U.S. Supreme Court’s decisions in South Dakota v. Wayfair and North Carolina Department of Revenue v. The Kimberly Rice Kaestner 1992 Family Trust, and recent state transfer pricing trends (coauthored with Sicilian and Snyder).

• Experience

Ms. Bossert serves as a Senior Technician Reviewer at the IRS Office of Chief Counsel, Procedure & Administration, Branch 6, in Richmond, Virginia, where she works primarily on matters involving the economic substance doctrine, the BBA partnership audit rules, and FOIA. She has also written on federal and multistate partnership tax procedure and state tax jurisdiction issues.

Julie Ciamporcero Avetta, Esq., Senior Attorney Advisor | Litigation, Tax Law Center at NYU School of Law

Julie Ciamporcero Avetta is a Senior Attorney Advisor focusing on litigation at the Tax Law Center at NYU Law. Previously, Julie litigated federal tax controversies at the trial and appellate levels, and served as counsel to several political appointees, in the Tax Division of the U.S. Department of Justice. Julie has authored more than seven dozen federal appellate and Supreme Court briefs, presented oral argument in 48 appeals, and won precedential victories in all 13 circuits of the U.S. Courts of Appeals.

• Education & Credentials

Julie earned a JD with honors from the University of Chicago Law School, where she was a member of the University of Chicago Law Review and received the Edwin F. Mandel Award for her work in the Appellate Advocacy Clinic. She also holds a BA in Linguistics, cum laude, from Yale College, and an MA in Media Studies from the New School for Social Research. She is admitted to practice law in Massachusetts, California, and Washington, DC.

• Recognition & Leadership

Julie received the Edwin F. Mandel Award for her work in the University of Chicago Law School’s Appellate Advocacy Clinic. She joined the U.S. Department of Justice through the Attorney General’s Honors Program, and over her career has won precedential victories in all 13 circuits of the U.S. Courts of Appeals.

• Professional Involvement

At the Tax Law Center at NYU Law, Julie’s recent work includes authoring amicus briefs in significant federal tax matters, such as the amicus brief in Soroban Capital Partners, LP v. Commissioner (March 2026) and the amicus brief in Denham Capital Management LP v. Bessent (December 2025).

• Experience

Julie focuses on litigation at the Tax Law Center at NYU Law. Previously, she litigated federal tax controversies at the trial and appellate levels and served as counsel to several political appointees in the Tax Division of the U.S. Department of Justice, where she authored more than seven dozen federal appellate and Supreme Court briefs, presented oral argument in 48 appeals, and won precedential victories in all 13 circuits of the U.S. Courts of Appeals. Before joining the Justice Department through the Attorney General’s Honors Program, Julie clerked on the Massachusetts Appeals Court for Judge Scott Kafker, now a Justice of the Massachusetts Supreme Judicial Court.

S. Starling Marshall, Esq., Partner | Crowell & Moring

S. Starling Marshall is a partner in the Litigation and Tax groups in Crowell & Moring’s New York office. A trial lawyer with over 15 years of experience, she has successfully represented clients before federal and state courts, arbitration panels, and administrative tribunals. When clients face complex commercial and tax disputes, they rely on Starling as their advocate and counselor, and she guides them toward business-minded solutions throughout all phases of an investigation or litigation. 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.

• Education & Credentials

Starling earned her B.A. from Emory University in 2002 and her J.D., cum laude, from Fordham University School of Law in 2005. She is admitted to practice in New York, as well as before the U.S. District Court for the Southern District of New York and the U.S. Court of Federal Claims.

• Recognition & Leadership

Starling has been recognized by Chambers USA for Litigation: General Commercial (New York, 2025) and Tax: Controversy (Nationwide, 2024–2025). She was named a Tax Law Trailblazer by The National Law Journal (2023), a Notable Woman in Law by Crain’s New York Business (2023), and “Lawyer of the Year” (New York) by The Best Lawyers in America (2022). She is a Fellow of the American College of Tax Counsel and served as Chair of the Federal Bar Association’s Section of Taxation (2021–2022). For her government service, the DOJ awarded her the Outstanding Attorney Award (2015) and the Special Commendation for Outstanding Contribution (2013). She also 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.

• Professional Involvement

Starling is a member of the J. Edgar Murdock Inn of Court (2013–present) and the Federal Bar Association – New York Chapter (2016–present), where she has served on the Taxation Steering Committee (2012present) and as Chair of the Section of Taxation (2021–2022). She is President of the Board of Directors of the Dave Nee Foundation (2013–present) and previously served as President of the Board of Directors of the Fordham Law Alumni Association of Washington (2012–2016). From 2012 to 2016, she was an Adjunct Professor at American University’s Washington College of Law. 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.

• Experience

Prior to entering private practice, Starling served as a trial attorney in the U.S. Department of Justice’s Tax Division, Court of Federal Claims Section, from 2009 to 2016, litigating cases before federal district courts and the Court of Federal Claims. She 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. From 2010 to 2014, she worked with the DOJ’s Office of Legal Policy to vet candidates for the federal judiciary. From 2008 to 2009, she served as a law clerk to the Honorable Victor Marrero of the U.S. District Court for the Southern District of New York. Today, drawing on her years of government service and private practice, she represents clients in all stages of litigation, complex IRS audits and administrative appeals, internal investigations, and criminal tax matters.

Ellen S. Brody, Esq., Partner | Roberts & Holland

Ellen Seiler Brody, for more than 20 years, has represented U.S. and international clients in tax controversy matters. Her clients include individuals, trusts, estates, corporations, and partnerships, including audits conducted under the IRS’s centralized audit regime of the Bipartisan Budget Act of 2015. Ellen represents clients during IRS audits and at appeals, as well as in litigation before the U.S. Tax Court, the U.S. Court of Federal Claims, and Federal district courts. She successfully litigated Grecian Magnesite, which overruled a long-standing IRS Revenue Ruling. Additionally, she is experienced with New York State and City tax controversy and has represented clients in matters involving personal income tax; corporate franchise tax; general corporation tax; unincorporated business income tax; commercial rent tax; and real estate transfer tax and real property transfer tax, representing clients during the audit, at conciliation, and in litigation before administrative bodies.

• Education & Credentials

Ellen earned her LL.M. in Taxation and her J.D., cum laude, both from New York University School of Law, and her B.S., magna cum laude, from the Wharton School of the University of Pennsylvania. She is admitted to practice in New York and New Jersey and is a Certified Public Accountant in South Dakota and New York. She is admitted before the United States Tax Court, the United States Court of Appeals for the Federal Circuit, the United States Court of Appeals for the District of Columbia Circuit, and the United States Court of Appeals for the Second Circuit.

• Recognition & Leadership

Ellen is a Fellow of the American College of Tax Counsel.

• Professional Involvement

Ellen has co-authored numerous Bloomberg Tax Portfolios (formerly BNA Tax Management Portfolios), including 537 T.M., Qualified Business Income Deduction: Section 199A; 539 T.M., Net Operating Losses — Concepts and Computations; 627 T.M., Limitations Periods, Interest on Underpayments and Overpayments, and Mitigation; 628 T.M., Transferee Liability; 630 T.M., Tax Court Litigation; and 631 T.M., Refund Litigation. She is a prolific author, contributing a recurring “In Case You Missed It” column and other articles to the New York State Society of CPAs’ TaxStringer, and has written for the New York Law Journal, Bloomberg BNA Daily Tax Report, and Tax Management International Journal on topics including microcaptive insurance arrangements, PFIC/QEF elections, the Qualified Business Income Deduction under Section 199A, voluntary disclosures, penalty avoidance, and New York residency and domicile. She is also a frequent speaker, including on a panel addressing the navigation of John Doe summonses at the Annual NYU Tax Controversy Forum.

• Experience

For more than 20 years, Ellen has represented U.S. and international clients in federal tax controversy matters, including individuals, trusts, estates, corporations, and partnerships, and audits conducted under the BBA centralized audit regime. She represents clients during IRS audits and at appeals, as well as in litigation before the U.S. Tax Court, the U.S. Court of Federal Claims, and Federal district courts, and successfully litigated Grecian Magnesite, which overruled a long-standing IRS Revenue Ruling. More recently, she secured a summary-judgment win for a client in the U.S. Court of Federal Claims in a tax refund case (Karp v. United States). Ellen also handles New York State and City tax controversy matters spanning personal income tax, corporate franchise tax, general corporation tax, unincorporated business income tax, commercial rent tax, and real estate and real property transfer taxes, representing clients during the audit, at conciliation, and in litigation before administrative bodies.

Jonathan Kalinski, Esq., Principal | Hochman Salkin Toscher Perez, PC

Jonathan Kalinski specializes in both civil and criminal tax controversies, as well as sensitive tax matters including disclosures of previously undeclared interests in foreign financial accounts and assets, and provides tax advice to taxpayers and their advisors throughout the world. He handles both Federal and state tax matters involving individuals, corporations, partnerships, limited liability companies, and trusts and estates. Mr. Kalinski has considerable experience handling complex civil tax examinations, administrative appeals, and tax collection matters.

• Education & Credentials

Mr. Kalinski earned an LL.M. in Taxation from New York University, his J.D. from Loyola Law School, and a B.A. in Political Science, with a minor in History, from the University of California, Santa Barbara. He is admitted to practice before the Supreme Court of California, the U.S. Tax Court, the U.S. District Court for the Central, Eastern, Northern, and Southern Districts of California, and the Ninth Circuit.

• Professional Involvement

Mr. Kalinski is a member of the American Bar Association Young Lawyers Division, Section of Taxation, and its Civil and Criminal Tax Penalties Committee; the California State Bar Association, Taxation Section; the Los Angeles Young Tax Lawyers, where he serves as a Board Member; the Los Angeles County Bar Association, Taxation Section; and the Beverly Hills Bar Association, Taxation Section. He is a frequent speaker on tax controversy topics, with recent presentations including “Current Employment Development Department Enforcement – What You Should Expect” (November 2025), “Navigating Tax Issues for Expats” (October 2025), “Partnership Audit Adjustments Under the Centralized Audit Regime” (October 2025), “Who Pays? Third-Party Responsibility in Tax Collection” (June 2025), “Taxation of Digital Asset Transactions Under Current Tax Law” for Strafford (April 2025), “Defending Tax Controversies Du Jour” at the 2025 USC Tax Institute (January 2025), and “IRS Collection Procedures and Best Practices” at the UCLA 40th Tax Controversy Institute (October 2024). His extensive speaking history also covers cannabis taxation, digital asset and cryptocurrency taxation, IRS international penalties after Farhy, partnership examinations under the centralized audit regime, employment tax disputes, and estate planning for difficult assets, before organizations including Strafford, CalCPA, the ABA Section of Taxation, the California Tax Bar, the Beverly Hills Bar Association, and the Los Angeles Estate Planning Council.

• Experience

Mr. Kalinski has considerable experience handling complex civil tax examinations, administrative appeals, and tax collection matters. Prior to joining the firm, he served as a trial attorney with the IRS Office of Chief Counsel, litigating Tax Court cases and advising Revenue Agents and Revenue Officers on a variety of complex tax matters. He also previously served as an Attorney-Adviser to the Honorable Juan F. Vasquez of the United States Tax Court. He handles both Federal and state tax matters involving individuals, corporations, partnerships, limited liability companies, and trusts and estates, and represents clients in sensitive matters including disclosures of previously undeclared foreign financial accounts and assets.

Matthew Cooper, Esq., Principal | Deloitte Tax

Matthew Cooper serves as Leader of the Federal Tax Controversy Group in Deloitte Tax LLP’s Washington National Tax Office, based in Washington, D.C. He is a recognized leader in tax law, with a distinguished career that bridges both public service and the private sector. Before joining Deloitte, Matt held a prominent position as special counsel at the IRS, where he provided strategic counsel to the IRS, the U.S. Department of Justice, tax practitioners, and the broader public, offering insight across a wide spectrum of administrative and judicial tax practice. His responsibilities included steering some of the agency’s most prominent initiatives, such as guiding the economic substance doctrine and launching the return preparer initiative, and he was a go-to resource for complex procedural tax matters—advising on penalties, refunds, the Tax Equity and Fiscal Responsibility Act, Circular 230, and power of attorney rules.

• Education & Credentials

Matt holds a JD from George Washington University Law School and a BS from Cornell University.

• Recognition & Leadership

A respected figure in the field, Matt frequently presents on tax controversy and ethics at major conferences, including those of the American Bar Association and the Federal Bar Association. He serves as a Council Member for the ABA Tax Section and is former chair of the ABA Tax Section’s Standards of Tax Practice Committee.

• Professional Involvement

Matt serves as a Council Member for the ABA Tax Section and is former chair of the ABA Tax Section’s Standards of Tax Practice Committee. He has also previously contributed as a member of the AICPA’s IRS Advocacy and Relations Committee and its Tax Practice and Procedures Committee. He frequently presents on tax controversy and ethics at major conferences, including those of the American Bar Association and the Federal Bar Association.

• Experience

Matt serves as Leader of the Federal Tax Controversy Group in Deloitte Tax LLP’s Washington National Tax Office. Before joining Deloitte, he was special counsel at the IRS, providing strategic counsel to the IRS, the U.S. Department of Justice, tax practitioners, and the public across administrative and judicial tax practice, including guiding the economic substance doctrine and launching the return preparer initiative, and advising on penalties, refunds, TEFRA, Circular 230, and power of attorney rules. His IRS tenure further included service as a senior technician reviewer supervising a team of 11 attorneys, where he contributed to the drafting of regulations, offered legal guidance, and supported litigation efforts on key issues including penalty provisions, statutes of limitation, interest, information reporting, and professional ethics. His work extended to the development of published guidance and critical projects, such as rules on reportable transaction penalties under Sections 6707, 6707A, and 6708; updates to employer identification numbers under Section 6109; estimated tax penalty relief under Section 6654; and all return preparer and Circular 230 initiatives since 2006. Matt’s experience is global as well as domestic: he completed a detail with Her Majesty’s Revenue & Customs in London, collaborating with the foreign profits team, and also served as special counsel to the IRS Director of the Office of Professional Responsibility.

Cory Ellenson, Esq., Managing Director | Andersen Tax

Cory Ellenson is a Managing Director in the US National Tax practice at Andersen, based in Washington, D.C., specializing in tax controversy. Cory has more than 13 years of experience navigating IRS audits and appeals and addressing IRS practice and procedure matters. He represents clients through all stages of IRS audits and appeals, including negotiating and responding to information document requests, negotiating proposed adjustments and settlements, and working with outside counsel to support and defend tax positions. Cory also resolves all IRS practice and procedure matters, including penalty abatement, voluntary disclosure, excise tax, employment tax, foreign and domestic information withholding and reporting, employee identification numbers, entity classification, R&D credit, transfer pricing, residency certifications, collection due process, and refund claims.

• Education & Credentials

Cory earned a BS in Accounting from the University of Southern California and a JD from the University of California, Los Angeles – School of Law. He is a member of the California State Bar and the United States Tax Court Bar.

• Experience

Cory has more than 13 years of experience navigating IRS audits and appeals and addressing IRS practice and procedure matters. He represents clients through all stages of IRS audits and appeals, including negotiating and responding to information document requests, negotiating proposed adjustments and settlements, and working with outside counsel to support and defend tax positions, and resolves all IRS practice and procedure matters, including penalty abatement, voluntary disclosure, excise tax, employment tax, foreign and domestic information withholding and reporting, employee identification numbers, entity classification, R&D credit, transfer pricing, residency certifications, collection due process, and refund claims. Before joining Andersen, Cory was at EY, where he led the Tax Controversy practice for all clients in the financial services industry across North and South America. Before EY, Cory was a practicing tax attorney with the IRS Office of Chief Counsel, where he litigated cases on behalf of the Commissioner of Internal Revenue in U.S. Tax Court and advised IRS agents as they conducted audits and appeals.

Zhanna A. Ziering, Esq., Managing Member | Ziering & Esman

Zhanna A. Ziering, a tax controversy and litigation attorney, is the Managing Member of Ziering & Esman PLLC, based in New York City. Ms. Ziering represents individual and entity taxpayers in civil and criminal tax matters before taxing authorities and enforcement agencies, including the Internal Revenue Service, the Department of Justice, and state tax authorities. She has represented clients in federal and state courts, including the United States Tax Court and the Court of Federal Claims. A zealous advocate for her clients, Ms. Ziering assists clients in all stages of the tax controversy and litigation cycle, approaching each client with compassion and understanding and working collaboratively to develop a strategy specifically tailored to the unique needs of each client. She also provides pro bono tax representation to artists across film, music, and fashion, and is committed to defending taxpayers facing penalties for international reporting noncompliance, frequently undertaking projects and cases on a pro bono basis. A native Russian speaker, Ms. Ziering lives in New Jersey.

• Education & Credentials

Ms. Ziering earned her LL.M. in Taxation from New York University School of Law, her Juris Doctor, magna cum laude, from New York Law School, and her Bachelor of Fine Arts from New York University. She is admitted in New York, New Jersey, and the District of Columbia, and before the U.S. Supreme Court, the U.S. Court of Appeals for the Second Circuit, the U.S. Tax Court, the U.S. Court of Federal Claims, and the U.S. District Courts for the Southern, Eastern, and Western Districts of New York and the District of New Jersey.

• Recognition & Leadership

Ms. Ziering is a Fellow of the American College of Tax Counsel. She has been recognized as a “Leading Lawyer” in US Taxes: Contentious (USA) by Legal 500 (2024) and as “Lawyer of the Year” in Litigation and Controversy–Tax (New York) by Best Lawyers (2023). She has been listed in The Best Lawyers in America for Tax Law (2025) and for Litigation and Controversy–Tax (2021–2025); in Chambers High Net Worth, USA, Tax: Private Client (2022–2024); in The Legal 500 as a Next Generation Lawyer (2018–present) and Recommended (2017–present); and in Super Lawyers in Tax, New York Metro (2023–2024), having earlier been named a New York Rising Star (2013–2017). She received The American Lawyer’s Global Legal Award, Global Dispute of the Year: Investigations, for the Swiss Tax Settlements (2015), and the Nolan Fellowship from the American Bar Association, Section of Taxation (2013).

• Professional Involvement

Ms. Ziering is a well-regarded member of the tax law community, serving as Chair of the Court Practice and Procedure Committee for the American Bar Association, Section of Taxation, where she has also been Vice-Chair of that committee and Co-Chair of the Subcommittee on Offshore Enforcement for the Civil and Criminal Tax Penalties Committee. She is also a member of the New York State Bar Association and the Federal Bar Association. A sought-after speaker and writer on tax controversy, tax litigation, and tax reporting compliance, she is co-author of the original and new edition of the Bloomberg BNA Tax Management Portfolio, “Report of Foreign Bank and Financial Accounts (FBAR),” and was a co-author of the Center for Taxpayer Rights’ amicus curiae brief in the U.S. Supreme Court case Bittner v. United States, which was quoted in the Court’s opinion. Her additional publications include articles for Bloomberg Tax, Law360 Tax Authority, CCH’s Journal of Tax Practice & Procedure, and The Practical Tax Lawyer, along with numerous ABA Section of Taxation comment submissions. She speaks frequently before the ABA, the NYU Tax Controversy Forum, the Federal Bar Association, and other organizations on FBAR litigation, civil and criminal tax penalties, voluntary disclosure, cryptocurrency enforcement, and ethics in tax practice.

• Experience

Ms. Ziering assists clients in all stages of the tax controversy and litigation cycle. Representative examples of her legal services include representing clients in district court litigation relating to FBAR penalties; advising U.S. citizens living or working abroad, foreign nationals residing and working in the U.S., and foreign entities doing business in the U.S. about coming into tax compliance concerning their foreign assets and business interests; representing clients in sensitive civil tax examinations by the IRS where fraud, substantial penalty issues, and/or criminal referral may arise; counseling advisors and other professionals on tax matters arising from investigations with U.S. regulators; defending clients in U.S. and state residency audits; advising clients throughout various stages of tax disputes with the IRS resulting from their domestic and offshore holdings; guiding clients through the IRS or state voluntary disclosure processes; representing clients in civil and criminal tax disputes with New York and New Jersey in connection with employment tax and sales tax issues; and defending clients in criminal investigations and civil examinations in connection with underpayments and/or underreporting of employment tax.

Jason B. Freeman, Esq., Managing Member | Freeman Law PLLC

Jason B. Freeman is the founding member of Freeman Law, PLLC. He is a dual-credentialed attorney-CPA, author, law professor, and trial attorney. 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, and 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, and frequently serves as an expert witness. He is also a Forbes contributor for tax and white-collar legal matters.

• Education & Credentials

Mr. Freeman earned his J.D. with High Honors and Order of the Coif from The University of Texas School of Law in 2009, where he was a student clerk for Justice Nathan L. Hecht of the Texas Supreme Court, Articles and Notes Editor of the Texas International Law Journal, and a research assistant for Professor Stanley M. Johanson. He also holds an M.P.A. in Accounting (2005) and a B.B.A. (2005), both from The University of Texas. He is admitted before the State Bar of Texas, the United States Tax Court, the United States Supreme Court, the U.S. Courts of Appeals for the Third, Fifth, and Seventh Circuits, and the U.S. District Courts for the Western, Northern, Eastern, and Southern Districts of Texas and the Northern District of Illinois.

• Recognition & Leadership

Mr. Freeman has been named by Chambers & Partners as among the leading tax and litigation attorneys in the United States (Tax: Fraud and Tax: Litigation) and to U.S. News and World Report’s Best Lawyers in America list (Tax Law, Criminal Defense: White-Collar, and Litigation and Controversy: Tax, including 2025 and 2026). He is a former recipient of the American Bar Association’s “On the Rise – Top 40 Young Lawyers” in America award and was named the “Leading Tax Controversy Litigation Attorney of the Year” for the State of Texas for 2019 and 2020 by AI. He is a Fellow of the American College of Tax Counsel (2025) and has been recognized multiple times by D Magazine as one of the Best Lawyers in Dallas and as a Super Lawyer by Super Lawyers, having earlier been recognized as a Top 100 Up-And-Coming Attorney in Texas and as the Young CPA of the Year in the State of Texas. He currently serves as chairman of the Texas Society of CPAs (TXCPA) and is a former chairman of the Dallas Society of CPAs (TXCPA-Dallas), and he served multiple terms as President of the North Texas chapter of the American Academy of Attorney-CPAs.

• Professional Involvement

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. His professional associations and memberships include the American Association of Attorneys-CPAs (President of the North Texas Chapter); the American Bar Association Section of Taxation; the State Bar of Texas, Section of Taxation (Tax Council Member, Co-Chair of the Committee on Government Submissions, and State Bar of Texas Tax Section Leadership Academy); the Dallas Bar Association (Tax Council, Co-Chairman of the Bench Bar Conference Committee, and former DBA Judiciary Committee member); the Dallas Association of Young Lawyers; the American Institute of Certified Public Accountants (Tax Practice and Procedures Committee and former member of the Tax Legislation and Policy Committee); the Texas Society of CPAs (Executive Board of Directors, 2016–2019; Director at Large, 2014–2016; Editorial Board; Federal Tax Policy Committee); the Dallas CPA Society (Board of Directors and Chairman of the CPE Committee); and the Dallas Regional Chamber of Commerce. He is a prolific author whose work has appeared in The Tax Adviser (AICPA), the Journal of Accountancy, Today’s CPA, the Texas Tax Lawyer, Dallas Bar Association Headnotes, and Forbes, addressing topics including partnership audit rules, micro-captive insurance, employment tax enforcement, international tax enforcement, cryptocurrency, and IRS penalties.

• Experience

Leveraging his CPA background, Mr. Freeman often represents clients in complex financial and regulatory matters involving 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 SEC and in asset forfeiture cases. His litigation experience includes serving as trial counsel in a criminal tax evasion and conspiracy jury trial in the Federal District Court for the U.S. Virgin Islands, and serving as lead appellate counsel presenting oral argument before the U.S. Court of Appeals for the Third Circuit. He is experienced in civil cases involving fraud, breach of fiduciary duty, civil RICO, executor and trustee litigation, complex probate litigation, negligence, trade secrets, partnership disputes, and breach of contract, and he also represents professionals—including attorneys and CPAs—before regulatory boards and in disciplinary hearings. Among his representative matters, he has obtained declinations to prosecute in multiple criminal tax investigations, secured “no-change” and reversal outcomes in IRS Global High Wealth and Puerto Rico Act 20/22 audits, obtained penalty abatements exceeding $14 million, won complete removal of a multi-million-dollar Texas franchise tax assessment, and obtained innocent spouse relief eliminating liabilities exceeding $1,000,000.

Jeffrey A. Neiman, Esq., Partner | Neiman Mays Floch & Almeida PLLC

When high-stakes legal issues arise, Jeffrey A. Neiman is the first call for countless CEOs, entrepreneurs, celebrities, and influencers. A former federal prosecutor and seasoned litigator, Jeff regularly advises clients on defending against government investigations, resolving complex business disputes, and navigating high-profile tax controversies. At his core, Jeff is a trial lawyer— having successfully tried more than a dozen white-collar cases in federal court. He is a frequent speaker, panelist, and contributor at national conferences on topics such as offshore tax evasion, tax fraud, Ponzi schemes, and trial strategy.

• Education & Credentials

A South Florida native, Jeff graduated with honors from the University of Florida, earning a B.S. in Finance, and from the University of Florida Levin College of Law, where he received his J.D. with Honors and was inducted into the Order of the Coif. He is admitted to practice in Florida and before the U.S. District Courts for the Southern, Middle, and Northern Districts of Florida and the United States Tax Court.

• Recognition & Leadership

Jeff was recognized by the Attorney General for his role in the landmark prosecution of UBS AG, Switzerland’s largest and oldest bank. His honors include the Attorney General’s John Marshall Award for Outstanding Legal Achievement, the Internal Revenue Service Commissioner’s Outstanding Achievement Award, finalist recognition for the Service to America Medal, and United States Department of Justice Outstanding Attorney Awards. In private practice, he has been recognized among Most Effective Lawyers (Criminal Justice), by Super Lawyers, and by Chambers & Partners.

• Professional Involvement

Jeff is a frequent speaker, panelist, and contributor at national conferences, addressing topics such as offshore tax evasion, tax fraud, Ponzi schemes, and trial strategy.

• Experience

Before founding Neiman Mays Floch & Almeida, Jeff spent a decade with the U.S. Department of Justice, serving in both Washington, D.C., and Miami. While working in the DOJ’s Tax and Criminal Divisions, he led investigations and prosecutions involving tax evasion, money laundering, public corruption, and securities and healthcare fraud, and was recognized by the Attorney General for his role in the landmark prosecution of UBS AG. Since entering private practice in 2011, Jeff has achieved exceptional results for his clients, both in court and behind the scenes. Notably, within a span of nine months, he secured a full acquittal in a federal criminal trial for an attorney charged with wire fraud and then won a jury verdict fully exonerating the heiress of an oil fortune in a civil matter where the government sought millions in penalties. Many of Jeff’s most significant victories occur quietly—resolving sensitive disputes discreetly and efficiently, often without the need for litigation. He regularly advises clients on defending against government investigations, resolving complex business disputes, and navigating high-profile tax controversies.

Chad M. Vanderhoef, Esq., Partner | Holland & Knight

Chad Vanderhoef is a tax attorney based in Holland & Knight’s Tampa and Washington, D.C., offices, where he focuses his practice on tax controversy and litigation, offshore tax and reporting compliance (such as Reports of Foreign Bank and Financial Accounts/FBARs and international information returns), cross-border tax planning, and foreign investment in U.S. real estate. His practice includes representing clients in tax controversy matters, including U.S. Tax Court and federal district and appellate court litigation, as well as IRS examination and appeals, and he advises clients in connection with IRS tax and reporting remediation options. Mr. Vanderhoef also advises clients in connection with cross-border restructuring matters, including foreign investment in U.S. real estate.

• Education & Credentials

Mr. Vanderhoef earned his LL.M. in Taxation from Georgetown University Law Center, his J.D. from Wake Forest University School of Law, an M.S. in Finance from Florida International University, and a B.B.A. in Finance from the University of North Florida. He is admitted to practice in the District of Columbia and Florida, and before the U.S. Supreme Court, the U.S. Tax Court, the U.S. Court of Federal Claims, the U.S. District Courts for the Southern, Northern, and Middle Districts of Florida, and the U.S. Courts of Appeals for the Tenth and Eleventh Circuits.

• Recognition & Leadership

Mr. Vanderhoef has been recognized in The Best Lawyers in America guide for Tax Law (2026). He serves on the Law360 Editorial Advisory Board, Tax Authority – International (2025 and 2026).

• Professional Involvement

Mr. Vanderhoef is a member of the Law360 Editorial Advisory Board, Tax Authority – International (2026), the American Bar Association, Section of Taxation, and The Florida Bar, Tax Section. He is an active author and speaker on tax topics, including presentations addressing the impact of the Supreme Court’s decisions in Loper Bright and Corner Post on tax regulations, and developments in FBAR compliance and enforcement.

• Experience

Mr. Vanderhoef’s practice includes representing clients in tax controversy matters, including U.S. Tax Court and federal district and appellate court litigation, as well as IRS examination and appeals, and advising clients in connection with IRS tax and reporting remediation options. He focuses on offshore tax and reporting compliance, including FBARs and international information returns, and advises clients on cross-border tax planning and cross-border restructuring matters, including foreign investment in U.S. real estate. Prior to joining Holland & Knight, Mr. Vanderhoef was a tax attorney for a boutique international tax law firm.

Amish Shah, Esq., Partner | Holland & Knight

Amish Shah is a tax attorney in Holland & Knight’s Washington, D.C., office. Mr. Shah focuses his practice on providing sophisticated and practical tax planning and tax controversy advice and representation to clients in the energy sector and to clients interested in achieving environmental, social and governance (ESG) goals through clean energy. He also advises clients in other sectors, including financial services, manufacturing, technology, and ecommerce. Mr. Shah has been advising clients with respect to energy tax credits for more than two decades across the full range of clean energy technologies, including production tax credits (PTCs) and investment tax credits (ITCs) for renewable power, alternative fuels, carbon capture, utilization and sequestration (CCUS), energy storage, hydrogen, biogas property, nuclear, and other technologies incentivized through tax credits, including under the Inflation Reduction Act. His representation spans the entire project life cycle, and he also represents clients in all phases of tax controversy at the administrative, trial court, and appellate levels, including many of the major energy tax controversy issues arising over the last two-plus decades.

• Education & Credentials

Mr. Shah earned his J.D., with honors, from The George Washington University Law School and his B.S. from the University of Maryland. He is admitted to practice in the District of Columbia and Maryland, and before the U.S. Tax Court, the U.S. Court of Appeals for the District of Columbia Circuit, and the U.S. Court of Appeals for the Fifth Circuit.

• Recognition & Leadership

Mr. Shah has been recognized in The Best Lawyers in America guide for Energy Law and Tax Law (20222026); by The Legal 500 USA for Energy: Renewable/Alternative Power (2015, 2021–2025), Energy: Transactions (2015), U.S. Taxes: Contentious (2019–2020, 2023–2025), and Tax – U.S. Taxes: NonContentious (2025); and in the Chambers USA guide for Tax (2021–2025). He was named among Leading Global Tax Lawyers by Lawdragon 500 (2025) and a Top Lawyer for Tax by The Washingtonian (2024), and he received the BTI Consulting Group Client Service Award (2015) and the Lexology Client Choice Award USA & Canada for Corporate Tax in Washington, D.C. (2013). He is a Fellow of the American College of Tax Counsel.

• Professional Involvement

Mr. Shah is Founder and Past Chair of the National Asian Pacific American Bar Association (NAPABA) and Chair of its Tax Committee. He is Past Chair of the American Bar Association (ABA) Section of Taxation’s Energy and Environmental Taxes Committee and a Fellow of the American College of Tax Counsel. He is a member of the District of Columbia Bar and the Maryland State Bar Association, a former Director and Vice President of the South Asian Bar Association of Washington, D.C. (SABA-DC), and has been involved with the George Washington Environmental Lawyer Law Journal. He is an active author and speaker on energy tax matters, including renewable energy tax credits, IRS appeals, and the Superfund tax on chemicals.

• Experience

Mr. Shah’s representation of clients spans across the project life cycle. He represents energy clients in seeking legislative and regulatory changes; in obtaining U.S. Department of the Treasury and IRS guidance, both public and private; in maximizing the value of tax credits, including through “begun construction” strategies; in project development, mergers and acquisitions, joint ventures, tax equity investments, and tax credit transfers; and in issuing and obtaining tax credit insurance. He also represents clients in all phases of tax controversy, including in many of the major energy tax controversy issues arising over the last two-plus decades, and in the development of and investment in traditional energy projects. His representative experience includes representing a client in the $1 billion-plus sale of a U.S. subsidiary to a UK publicly traded company; representing clients in the purchase and sale of tax credits across various industries; representing a multinational pipeline company in acquiring shovel-ready wind power projects in Texas (249 MW) and West Virginia (103 MW); advising a global renewable power producer on the U.S. legal aspects of acquiring a Canadian renewable energy company with assets across multiple countries; representing several paper-industry clients in obtaining and supporting alternative fuel mixture tax credit claims for black liquor; advising renewable natural gas producers on project development and M&A transactions; and representing a client in a complex, long-running “Son-of-Boss” dispute in the Tax Court and the U.S. Court of Appeals for the District of Columbia Circuit. Mr. Shah began his career as a certified public accountant (CPA)/tax accountant at a Big 6 accounting firm and draws on that experience to provide clients with practical advice across both tax planning and controversy.

Carina C. Federico, Esq., Partner | Crowell & Moring

Carina Federico is a partner in Crowell & Moring’s Tax Group, resident in the firm’s Washington, D.C. office. She handles tax disputes at all stages, including IRS audits, IRS Appeals, federal district court litigation, tax court litigation, and appellate court litigation across the United States. Her experience includes serving as first chair at trial, taking and defending depositions, briefing a wide range of tax issues, negotiating settlements, and representing clients in IRS Appeals conferences. Carina counsels clients on tax policy matters by engaging regularly with key stakeholders at the Department of the Treasury and the Internal Revenue Service on behalf of clients seeking regulatory changes or clarity in existing regulations, and by submitting comments on proposed regulations and other guidance. She also advises taxpayers interested in claiming tax credits and incentives, including the energy tax credits under the Inflation Reduction Act.

• Education & Credentials

She practices in Washington, D.C., handles litigation in trial and appellate courts across the United States, and previously served as a trial attorney at the U.S. Department of Justice, Tax Division.

• Recognition & Leadership

Carina was awarded the Nolan Fellowship by the ABA Section of Taxation for 2020–2021, a distinction given to young lawyers who are actively involved in the Section and have demonstrated leadership and a commitment to their community. She is recognized in the Chambers USA guide as an up-and-coming tax controversy attorney noted for her expertise in advising clients in tax controversy and tax litigation. During her government service at the DOJ Tax Division, she received the Tax Division’s Outstanding Attorney Award (2014) and a Special Commendation (2013).

• Professional Involvement

Carina is actively involved in the ABA Section of Taxation, where she has served as a reporter for the ABA U.S. and Europe Tax Practice Trends conference and as a moderator at the ABA May Tax Meeting. She is a frequent speaker on tax controversy and energy tax credit topics, including at the Novogradac Fall Renewable Energy Tax Credit Conference and the TEI Midyear Conference, and she counsels clients on tax policy by engaging with the Treasury Department and IRS and submitting comments on proposed regulations and guidance.

• Experience

Carina handles tax disputes at all stages, including IRS audits, IRS Appeals, federal district court litigation, tax court litigation, and appellate court litigation across the United States, with experience serving as first chair at trial, taking and defending depositions, briefing a wide range of tax issues, negotiating settlements, and representing clients in IRS Appeals conferences. She also advises taxpayers on claiming tax credits and incentives, including energy tax credits under the Inflation Reduction Act, and counsels clients on tax policy matters. Carina previously was a trial attorney at the U.S. Department of Justice, Tax Division, where she represented the IRS as lead counsel in civil actions, contested matters, and adversary proceedings before the U.S. District and Bankruptcy Courts, as well as in bankruptcy appeals before U.S. District Courts. She also served as deputy associate counsel for the White House, where she was the tax counsel on the vetting team for presidential nominations and appointments, and she was seconded to Ernst & Young as a legal consultant to the general counsel’s office, advising EY engagement teams on tax controversy issues including requests for penalty abatement and tax advice for audit clients.

Joshua D. Smeltzer, Esq., Partner | Gray Reed

Joshua D. Smeltzer is an experienced trial lawyer, Board Certified tax law specialist, and trusted advisor to corporations, partnerships, family offices, and high-net-worth individuals, based in Gray Reed’s Dallas and Houston offices. A former trial attorney with the U.S. Department of Justice, Joshua brings more than two decades of government and private-sector experience to high-stakes civil and criminal federal court litigation across the country, with matters ranging from $500,000 to over $1.5 billion. Chair of the Tax Controversy & Litigation practice and co-chair of the firm’s Blockchain and Digital Asset practice, he focuses on distilling highly technical tax, financial, and regulatory issues into clear themes that resonate with judges, juries, and government agencies, and he represents clients through every stage of a controversy with the federal government, including complex litigation in federal district courts, the U.S. Tax Court, and other federal forums. His litigation and advisory work spans financial services, private equity, energy, real estate, and emerging technologies such as artificial intelligence and digital assets. A recognized thought leader on tax, corporate governance, digital assets, and regulatory compliance, Joshua serves as editor of Gray Reed’s Dollars & Sense blog and contributes regularly to Forbes and other national publications.

• Education & Credentials

Joshua earned his J.D., magna cum laude, from American University Washington College of Law in 2004, where he was inducted into the Order of the Coif, served as Executive Editor of the Administrative Law Review, and held a Dean’s Fellowship for the Legal Writing Department. He received his B.S. in Psychology from the University of Utah in 2000, where he was named to the Dean’s List and the Golden Key and Psi Chi National Honor Societies. He is admitted to practice in Texas (2019) and Maryland (2004), and is Board Certified in Tax Law by the Texas Board of Legal Specialization. He is admitted before the United States Tax Court, the U.S. Court of Federal Claims, the U.S. Court of International Trade, the U.S. Courts of Appeals for the Fifth and Ninth Circuits, the U.S. District Courts for the Northern, Eastern, Southern, and Western Districts of Texas and the District of Maryland, and the U.S. Bankruptcy Courts for the Northern, Eastern, Southern, and Western Districts of Texas.

• Recognition & Leadership

Joshua has been selected by his peers for inclusion in The Best Lawyers in America in Tax Law (2024–2026) and Tax Litigation (2025–2026), as a Best Lawyer in Dallas by D Magazine (2024–2026), and as a “Super Lawyer” by Texas Super Lawyers as published in Texas Monthly (2022–2025). During his service at the U.S. Department of Justice, Tax Division, he received seven Outstanding Attorney Awards (2007, 2008, 2010, 2013, 2015, 2017, and 2018).

• Professional Involvement

Joshua is a member of the American Bar Association – Tax Section, the Federal Bar Association – Tax Section, and the State Bar of Texas – Tax Section, where he served as Co-Chair of the Tax Controversy Committee (2022–2024) and as a Council Member (2023–2026). He served as a Board Member of the North Dallas Chamber of Commerce (2021–2025) and is involved with the Texas Blockchain Council (2022present), including its Financial Services Committee (2023–present), and serves as Corporate Advisor to the New Jersey Blockchain Council (2022–present). He is editor of Gray Reed’s Dollars & Sense blog, a regular Forbes contributor, and a frequent speaker at conferences and symposiums in the United States and internationally.

• Experience

Joshua represents clients through every stage of federal tax controversy and litigation. His representative tax controversy matters include obtaining a favorable Tax Court decision denying a $120 million proposed deficiency involving real estate investments by a family office; obtaining the release of a $1.5 billion nominee lien filed against a client’s property; obtaining no-change letters for multiple clients facing highdollar IRS audit examinations; and negotiating favorable settlements at the IRS Independent Office of Appeals, including penalty reductions over $1 million and lien releases. He has handled matters at hearings and trial in the U.S. Tax Court, federal district courts throughout the country, the Court of Federal Claims, and U.S. Bankruptcy Courts, and has advised and represented corporate clients on IRS and DOJ priority issues involving ERC tax credits, micro-captive insurance arrangements, syndicated conservation easement arrangements, and other partnership, trust, or charitable-donation structures. In tax and business planning, he has advocated for relief through the IRS Private Letter Ruling process, advised on the structuring of technology-focused partnerships, advised on a multi-million-dollar renewable energy transaction involving carbon capture, and advocated before the IRS Competent Authority for relief from double taxation under international tax treaty provisions. In the blockchain and digital asset space, he regularly advises digital asset and blockchain technology companies and investors on regulatory compliance, corporate structure, and tax issues; defended an early Bitcoin investor against criminal allegations in one of the first criminal tax indictments involving cryptocurrency; obtained a complete dismissal of an SEC complaint alleging over $1 billion of unregistered securities and fraud claims against a blockchain technology entrepreneur; and obtained a significant settlement on behalf of the Texas Blockchain Council, Riot Platforms, Inc., and the Digital Chamber of Commerce against the Department of Energy, the Energy Information Administration, and the Office of Management and Budget. Before entering private practice, Joshua served as a trial attorney with the U.S. Department of Justice, Tax Division.

Kathleen King, CPA, Managing Director | Alvarez & Marsal Tax

Kathleen King is a Managing Director and National R&D Practice Leader with Alvarez & Marsal Tax, LLC in Washington, D.C. With more than 25 years of experience, Ms. King specializes in assisting clients in claiming, documenting, and sustaining tax incentives, including research tax credits, the meals and entertainment deduction, energy credits, work opportunity tax credits, and state credits. She has worked with clients across various industries, including aerospace and defense, food products, manufacturing, pharmaceutical products, retail, and software. Her projects have ranged from targeted consulting engagements designed to address specific issues to large-scale projects utilizing engagement teams working concurrently in multiple locations.

• Education & Credentials

Ms. King earned a bachelor’s degree in mineral land management from the University of Colorado and a master’s degree in accounting from American University in Washington, D.C. She is a Certified Public Accountant.

• Recognition & Leadership

Ms. King serves as Alvarez & Marsal Tax’s National R&D Practice Leader.

• Professional Involvement

Ms. King is an active author and thought leader on tax incentives and credits, contributing insights on topics including hidden risks in incentive agreements during M&A transactions, securing local incentives through Texas Chapter 312 and 380/381 agreements, and federal tax reform developments.

• Experience

Ms. King specializes in helping clients claim, document, and sustain tax incentives, including research tax credits, the meals and entertainment deduction, energy credits, work opportunity tax credits, and state credits. She has extensive experience leading research credit analyses and representing clients in audits performed by the Internal Revenue Service and state tax authorities at the field and appeals levels, and her engagements have ranged from targeted consulting projects to large-scale, multi-location efforts across industries such as aerospace and defense, food products, manufacturing, pharmaceuticals, retail, and software. Prior to joining A&M, Ms. King served as a national resource for the Research Credit Services teams with Big Four firms.

Andrew Weiner, Esq., Counsel | Kostelanetz

Andy Weiner is Counsel with Kostelanetz LLP, based in the firm’s Washington, D.C. office. He focuses on tax controversies, both civil and criminal, in trial and appellate courts and at the agency level. A Fellow of the American College of Tax Counsel, Andy is a frequent writer and speaker on tax issues. He has handled a wide diversity of matters in areas such as partnership taxation, corporate taxation and reorganizations, taxation of S corporations, tax accounting methods, income tax, gift and estate taxes, and collections, combining a deep knowledge of tax law with extensive litigation and administrative practice experience.

• Education & Credentials

Andy earned his LL.M. in Taxation from Georgetown Law Center, his J.D., cum laude, from the University of Pennsylvania Law School, and his B.A., magna cum laude, from Bowdoin College. He is admitted to practice in the District of Columbia and California.

• Recognition & Leadership

Andy is a Fellow of the American College of Tax Counsel. During his tenure at the U.S. Department of Justice, Tax Division, he received the Tax Division’s Outstanding Attorney Award five times and was awarded a Special Commendation.

• Professional Involvement

Andy authored the chapter on “Applying Administrative Law in Tax Cases” in the upcoming 9th edition of Effectively Representing Your Client Before the IRS, published by the ABA Tax Section. He currently serves as vice chair of the ABA Tax Section Diversity Committee and as vice chair of the D.C. Bar Tax Audits and Litigation Committee, and he is an adjunct professor at American University Washington College of Law. He is a frequent writer and speaker on tax issues, with recent publications including “Jarkesy, Originalism, and the Future of Tax Penalties” (April 2026) and “Can Tax Promoter Penalties be ‘Excessive Fines’ Under the Eighth Amendment?” (October 2025), and recent speaking engagements including “Nuts and Bolts of a BBA Partnership Audit” at NYU (June 2026) and a session on tax refund claims and litigation at the Texas Federal Tax Institute (June 2026).

• Experience

Andy focuses on civil and criminal tax controversies in trial and appellate courts and at the agency level. Prior to joining Kostelanetz, he was a trial attorney for over a decade with the U.S. Department of Justice, Tax Division, where he briefed and argued approximately 50 cases before the United States courts of appeals and handled several significant matters in the Court of Federal Claims focused on tax shelters, research and energy credits, FBAR penalties, and Administrative Procedure Act claims. He also spent four years in academia as Director of the Graduate Tax Program and founding Director of the Low Income Taxpayer Clinic, as well as a Practice Professor of Law, at Temple University Beasley School of Law. He has handled a wide diversity of matters in partnership taxation, corporate taxation and reorganizations, taxation of S corporations, tax accounting methods, income tax, gift and estate taxes, and collections.

Joshua Wu, Esq., Deputy Assistant Attorney General for the Tax Litigation Branch | US Department of Justice, Civil Division

Joshua Wu serves as the Deputy Assistant Attorney General for the Tax Litigation Branch of the Civil Division of the U.S. Department of Justice, a role he has held since 2025. He rejoined the Department from Latham & Watkins LLP in Washington, D.C., where he practiced in the firm’s tax controversy and litigation group, counseling and advocating for companies and high-net-worth individuals on all aspects of tax controversies and litigation. He previously served at the Department from 2019 to 2021 as Deputy Assistant Attorney General for Appellate and Review in the Tax Division, where he oversaw virtually all appeals in civil federal tax cases throughout the country and managed a 40-lawyer team. In that role he also represented the United States in appellate oral arguments, evaluated and approved significant civil settlement offers, furnished advice to the Tax Division’s trial sections in complex tax cases, led the operational functions of the Tax Division, and led the Office of Legislation and Policy, which works with the Department of the Treasury, the IRS, and other agencies on legislative, regulatory, and policy initiatives.

• Education & Credentials

Josh earned his LL.M. in Taxation from the Georgetown University Law Center. He is a graduate of the Syracuse University College of Law and the University of Virginia.

• Recognition & Leadership

In October 2024, Josh was inducted as a Fellow of the American College of Tax Counsel, a nonprofit association of tax attorneys recognized for excellence in tax practice and substantial contributions to the legal profession. Election as a Fellow requires nomination by a current Fellow and evaluation by a committee of the College’s Board of Regents, with membership criteria including bar membership in one or more states for at least 15 years, a career principally devoted to tax law and tax-related matters, and a demonstrated high standard of excellence and ethical conduct in the practice of tax law. He has also been identified by Legal 500 as a key practitioner within Latham & Watkins’ contentious tax practice.

• Professional Involvement

In private practice, Josh advised large companies and high-net-worth individuals on all aspects of federal tax law and controversies, with a practice focused on litigating high-stakes tax cases and representing clients in both civil and criminal tax controversy matters. His advisory work spans tax accounting disputes, corporate and partnership transactional issues, international questions, employee benefits matters, transfer pricing, and tax-exempt controversies. He has served as a featured speaker on tax matters, including on voluntary disclosure programs and the Section 199A pass-through deduction, and has presented before professional audiences such as CPA societies and international tax symposia.

• Experience

Joshua Wu serves as the Deputy Assistant Attorney General for the Tax Litigation Branch of the Civil Division (2025–Present), one of seven deputy assistant attorneys general in the Civil Division reporting to the Assistant Attorney General. Immediately before this role, he was counsel in the Tax Department and a member of the Tax Controversy Practice at Latham & Watkins LLP in Washington, D.C., where he advised companies, tax-exempt organizations, and high-net-worth individuals on resolving contentious tax matters. From 2019 to 2021, he served at the Department of Justice as Deputy Assistant Attorney General for Appellate and Review in the Tax Division, overseeing civil federal tax appeals nationwide, managing a 40-lawyer team, arguing appeals on behalf of the United States, approving significant civil settlements, advising the Tax Division’s trial sections, and leading the Office of Legislation and Policy. Earlier in his career he worked as an associate at Latham & Watkins and as a partner at a large international law firm.

Don Fort, CPA, Senior Investigator | Kostelanetz

John D. (Don) Fort is a Senior Investigator at Kostelanetz LLP and the former 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 an extensive network of connections both within the government and in private industry. At the 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, with particular expertise in investigations involving cryptocurrency and cannabis-related matters. He also conducts internal investigations, advises clients on compliance regimes, and 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, and serves as Chief Business Officer with IVIX.

• Education & Credentials

Don holds a Bachelor of Arts degree in Management from Gettysburg College (1990) and is a licensed Certified Public Accountant in the State of Virginia.

• Recognition & Leadership

In 2020, Don was the recipient of the Association of Certified Anti-Money Laundering Specialists (ACAMS) Public-Private Partnership Award. As Chief of IRS-CI from 2017 to 2020, he 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 across 21 IRS field offices and 11 foreign countries. As both Chief and Deputy Chief, he oversaw numerous high-profile matters, including the “Varsity Blues” college admissions scandal; the Paul Manafort, Michael Cohen, and Michael Avenatti federal tax investigations; the takedown of the largest darknet child exploitation website funded by cryptocurrency; the prosecution of two Chinese nationals charged with laundering $100 million in a cryptocurrency exchange hack; the Swiss Bank Program, in which 80 Swiss banks entered agreements and paid $1.36 billion in penalties; the FIFA worldwide money laundering, structuring, and tax evasion matter; and the Credit Suisse guilty plea.

• Professional Involvement

Don is an accomplished public speaker who serves as an expert in law enforcement, leadership, financial crimes, and enhancing public-private partnerships. He has extensive experience briefing high-level government officials, has testified before Congress, and has provided numerous briefings to congressional staff. He serves on the advisory boards of several fintech, anti-money laundering, cryptocurrency, and cannabis compliance companies, including AML RightSource, ZenLedger, and NCS Analytics, and holds the role of Chief Business Officer at IVIX. He participates regularly in leading tax and economic crime programs, including the ABA Criminal Tax Fraud and Tax Controversy meeting, the Hawaii Tax Institute, and the Cambridge International Symposium on Economic Crime.

• Experience

Don served with the U.S. Department of the Treasury, Internal Revenue Service, Criminal Investigation (IRS-CI) from August 1991 to September 2020, spending the final nine years as a member of the Senior Executive Service. He began as a Special Agent in the Washington, D.C. Field Office (1991–1999), then served as Supervisory Special Agent in Orlando (1999–2003); Section Director/Senior Analyst for Special Investigative Techniques in Washington, D.C. (2003–2006); Assistant Special Agent in Charge of the Baltimore and Washington, D.C. Field Offices (2006–2009); Special Agent in Charge of the Philadelphia Field Office (2009–2010); Deputy Director of Strategy at Washington, D.C. Headquarters (2010–2011); Director of Field Operations for the Western and Northern Areas (2011–2014); Deputy Chief of IRS-CI (2014–2017); and Chief of IRS-CI (2017–2020). His tenure included oversight of investigations into 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. Since leaving government in 2020, he has served as Director of Investigations and now Senior Investigator at Kostelanetz LLP, operating out of the firm’s Washington, D.C. office.

Guy Ficco, CFE, Senior Investigator | Kostelanetz

Guy Ficco is a Senior Investigator at Kostelanetz LLP and the immediate past Chief of IRS Criminal Investigation (IRS-CI). As Chief and Deputy Chief of IRS-CI from 2022 through April 2026, Guy directed one of America’s largest federal law enforcement organizations, overseeing operations with an annual budget exceeding $1 billion and leading a global workforce of approximately 3,500 personnel, including more than 2,300 special agents deployed across 20 domestic field offices and operations in 14 international locations. Throughout his law enforcement career, he spearheaded investigations into major financial crimes spanning tax evasion, sanctions violations, money laundering, corruption, banking misconduct, cybercrime, cryptocurrency offenses, and terrorism financing. At the firm, he draws on more than 30 years of federal law enforcement experience to advise clients on matters including criminal tax exposure, parallel civil-criminal investigations, Bank Secrecy Act and anti-money laundering issues, cryptocurrency enforcement, corporate compliance, and cross-border financial crime.

• Education & Credentials

Guy earned his Bachelor of Business Administration degree, with a concentration in accounting, from Dominican University (New York). He is a Certified Fraud Examiner and maintains professional memberships in both the Association of Certified Fraud Examiners (CFE) and the Association of Certified Sanctions Specialists.

• Recognition & Leadership

During Guy’s tenure, IRS-CI achieved record enforcement results, expanded its international footprint, and strengthened collaboration with domestic and foreign law enforcement agencies. In his roles as both Chief and Deputy Chief, he directed several landmark investigations, including Janet Mello’s $100 million grant fraud scheme, a $1 billion syndicated conservation easement tax fraud conspiracy, the comprehensive $1 billion Bank Secrecy Act and IEEPA investigation of Binance, a major biofuel tax conspiracy, and multiple prominent darknet marketplace cases involving narcotics trafficking, cybercrime, identity theft, and child exploitation materials. He co-chaired the Treasury Department’s Fentanyl Strike Force and led IRS-CI’s participation in the United States’ “Task Force KleptoCapture” following Russia’s invasion of Ukraine. His international leadership roles included serving on the Executive Policy Board for the International Law Enforcement Academy (ILEA), active participation in the OECD Task Force on Tax Crimes and Other Crimes (TFTC), and chairing the OECD Tax Crimes Enforcement Network (TCEN). He also represented the United States as Chief of IRS-CI as part of the Joint Chiefs of Global Tax Enforcement (J5).

• Professional Involvement

As an established expert in financial crime enforcement, Guy regularly addresses domestic and international audiences on complex white-collar fraud, cryptocurrency investigations, and anti-money laundering compliance. Under his leadership, IRS-CI launched an innovative Public-Private Partnership initiative (CI FIRST) designed to foster collaboration between law enforcement and Bank Secrecy Act filers, including financial institutions, casinos, and money service businesses. He championed a data-driven transformation within IRS-CI, cultivating a new generation of analytically minded leaders and introducing innovations such as an artificial intelligence tool that assesses prosecution likelihood during investigation initiation phases. He completed a congressional fellowship with the Permanent Subcommittee on Investigations for Homeland Security and Governmental Affairs, contributing to oversight investigations examining international tax shelters, corporate stock option abuses, and credit card fraud, and he has regularly briefed senior government officials and congressional staff on critical matters. He maintains memberships in the Association of Certified Fraud Examiners and the Association of Certified Sanctions Specialists.

• Experience

Guy began his IRS career in 1995 as a Special Agent in New York, progressively advancing through various supervisory positions before joining the Senior Executive Service in May 2020 as Executive Director of Global Operations, a role he held until his appointment as Deputy Chief in July 2022. He subsequently served as Chief of IRS-CI, leading the agency through April 2026. Across his career he held a range of CI leadership roles, including Special Agent in Charge of the Philadelphia Field Office (2018–2020), Supervisory Special Agent in the Washington Field Office, and senior analyst and executive positions spanning financial crimes, international operations, and global policy and support. During his tenure as Chief and Deputy Chief, he oversaw the agency’s worldwide enforcement operations and directed many of its most consequential domestic and cross-border criminal tax and financial crime investigations. Since leaving government in 2026, he has served as a Senior Investigator at Kostelanetz LLP.

Jarod Koopman, Chief, Criminal Investigation Division; Chief Tax Compliance Officer | Internal Revenue Service

Jarod Koopman is the Chief of IRS Criminal Investigation (IRS-CI) and the agency’s Chief Tax Compliance Officer. He stepped into the Chief role after more than 26 years with the IRS, including over two decades within IRS-CI, where he has held leadership positions at multiple levels. As Chief of IRSCI, he leads a global workforce of approximately 3,000 personnel, including more than 2,100 special agents operating across 20 field offices and 11 international locations. As Chief Tax Compliance Officer, he oversees IRS compliance operations across several major divisions and offices, including the Large Business and International division, the Small Business/Self-Employed division, the Tax Exempt and Government Entities division, IRS Criminal Investigation, the Office of Professional Responsibility, the Return Preparer Office, and the Whistleblower Office. He is widely respected as a global leader in cryptocurrency tracing and dark web investigations.

• Education & Credentials

A native of Upstate New York, Jarod is a graduate of Nazareth University in Rochester. He began his law enforcement career in 2002 following his training at the Federal Law Enforcement Training Center (FLETC), excelling in both FLETC’s Criminal Investigator Training Program and IRS-CI’s Special Agent Basic Training Program and graduating at the top of his class.

• Recognition & Leadership

Under Jarod’s leadership, IRS-CI significantly enhanced its capabilities, establishing itself as a global leader in cryptocurrency tracing and dark web investigations. As director of cybercrime for IRS-CI, he helped achieve major wins against crimes involving cryptocurrency, including the dismantling of the Silk Road dark web marketplace, which led to the government seizing $3.36 billion worth of bitcoin. In 2011 he was selected for the Accelerated Senior Leadership Program (ASLP). Upon his appointment as Chief, IRS-CI publicly recognized that over his then-26-year career he had established himself as a leader and innovator within the agency. His work has also been recognized in the bestselling book Who Is Government? by Michael Lewis and featured in the Washington Post series “Cyber Sleuth.”

• Professional Involvement

Jarod is recognized as an expert on financial crime, cryptocurrency tracing, and anti-money laundering enforcement, and he addresses law enforcement and compliance audiences on these topics, including as a speaker at the 2026 West Coast Anti-Money Laundering (WCAML) Forum. In 2015, he was tasked with establishing and leading IRS-CI’s Cyber Crimes and Cyber and Forensics Services sections, serving as Director of both. Earlier in his career, after transitioning to IRS Headquarters as a Senior Analyst, he worked under the direction of the National Identity Theft Coordinator, contributing to the agency’s heightened focus on identity theft as a national priority in 2012.

• Experience

Jarod began his law enforcement career with the IRS in 2002 as a special agent in Rochester, New York. In April 2010, he was promoted to Supervisory Special Agent for the Western District of New York, and the following year he was selected for the Accelerated Senior Leadership Program and transitioned to IRS Headquarters as a Senior Analyst, working under the National Identity Theft Coordinator. Beginning in 2015–2016 as a CI executive, he led the creation and development of both the Cyber Crimes and Cyber and Forensics Services sections, serving as Director of each. He later served as Assistant Special Agent in Charge of the Chicago Field Office, then as Special Agent in Charge of the Detroit Field Office, and as Executive Director of Northern Field Operations, overseeing criminal investigative activities across 17 states. In October 2025 he was named Acting Chief Tax Compliance Officer, overseeing the agency’s enforcement divisions, and effective April 2026 he was named Chief of IRS Criminal Investigation while continuing to serve as Chief Tax Compliance Officer.

Karen E. Kelly, Esq., Partner | Kostelanetz

Karen Kelly is a Partner in the Washington, D.C. office of Kostelanetz LLP and the former head of the Justice Department’s Tax Division. She joined the firm after more than 30 years of federal and state trial practice, including prosecuting tax and white-collar crime. Her practice focuses on representing clients in state and federal civil tax controversies, defending clients in government investigations involving criminal tax and white-collar matters and against state and federal criminal charges, conducting internal investigations, representing legal and tax professionals and their firms in license and regulatory matters, and complex civil and criminal litigation. She most recently served at the Department of Justice as the Acting Assistant Attorney General and delegated component head of the Tax Division, where she supervised all federal civil and criminal tax matters assigned to the Department throughout the country, along with more than 300 trial and appellate attorneys. First and foremost a litigator, Karen led and managed hundreds of sophisticated grand jury investigations and criminal tax jury trials in federal district courts nationwide.

• Education & Credentials

Karen received her law degree, cum laude, from Syracuse University College of Law and her bachelor’s degree from the College of the Holy Cross. She is admitted to practice in the District of Columbia and the Eastern District of Virginia.

• Recognition & Leadership

Karen received numerous commendations recognizing her extraordinary government service. She was twice honored with the Department of Justice Attorney General’s Award — among the highest service awards issued by the Department — including the Attorney General’s Award for Outstanding Service (2014) and the Attorney General’s Distinguished Service Award (2011) for her contributions as a member of a public corruption task force. She received the IRS Criminal Investigation Chief’s Award (2007) for her successful prosecution of a telecommunications entrepreneur who evaded more than $200 million in taxes — the largest individual income tax evasion case at the time — as well as the Department of Justice Executive Office Director’s Award for Superior Performance in Litigation (2009). She has been the recipient of more than a dozen Tax Division Outstanding Attorney Awards (2000, 2002, and 2005 through 2018), the Department of Justice Outstanding Mentor Award (2010), and the United States Attorney’s Office for the District of Columbia Outstanding Merit recognition (2003).

• Professional Involvement

Karen is a member of the American Bar Association (Section of Taxation; White Collar and Criminal Litigation), the National Association of Criminal Defense Attorneys (Lawyers), the Virginia State Bar (Section of Taxation; Litigation), and the Virginia Women’s Attorney Association. She currently serves on the Virginia State Bar Disciplinary Committee, reviewing attorney disciplinary complaints and investigations and conducting disciplinary hearings, having also served on the Committee from 2014 through 2018. A frequent lecturer, she has presented at U.S. Attorneys’ Offices on tax crimes, grand jury investigations, trial practice, and prosecutions, and as part of her government service she trained dozens of attorneys, law enforcement agents, and IRS personnel in the United States and abroad — including at the Justice Department’s training center in South Carolina, at IRS Field Offices, and in international engagements with Serbian law enforcement and the Barbados Revenue Authority. She regularly speaks on tax enforcement issues at ABA-sponsored conferences and other tax bar events.

• Experience

Karen served with the Tax Division of the U.S. Department of Justice in Washington, D.C., as Delegated Component Head and Acting Deputy Assistant Attorney General (2025), Chief of the Southern Criminal Enforcement Section (2019–2025), Assistant Chief of the Northern Criminal Enforcement Section (20082019), and Trial Attorney in the Northern Criminal Enforcement Section (1997–2008). During her career as a federal prosecutor she handled crimes including tax evasion, conspiracy, payroll tax fraud, obstruction, money laundering, FBAR violations, false claims, nominee entities, identity theft, false tax filings, and complex tax shelters, and she assisted with the Department’s Swiss Bank Program and resolved complex offshore entity investigations. As Assistant Chief and later Chief, she worked with federal prosecutors in more than 40 U.S. Attorneys’ Offices, coordinated and managed the Tax Division criminal portfolio, and built a strong working relationship with IRS Criminal Investigation; her successes include the first successful criminal prosecution of multiple professionals involved in the creation and promotion of a syndicated conservation easement tax shelter. She also served as a Special Assistant U.S. Attorney in the Southern District of New York (white-collar prosecutions) and in the Southern District of California (immigration and narcotics crimes), and earlier prosecuted state crime as an Assistant Commonwealth’s Attorney in Fairfax County, Virginia (1994–1997). Since 2025, she has practiced as a Partner at Kostelanetz LLP.

Scott Levine, Esq., Partner | Baker McKenzie

Scott Levine is a partner in Baker McKenzie’s Tax Practice Group, based in the Firm’s Washington, D.C. office. Prior to joining the Firm, Scott most recently served as the Deputy Assistant Secretary (International Tax Affairs) in the U.S. Department of the Treasury, where he led the Office of Tax Policy’s work on international affairs, including regulations, treaties, and the OECD/G20 Inclusive Framework on BEPS negotiations on Pillar 1 and Pillar 2. He has significant experience advising multinational companies on the tax aspects of corporate transactions, including cross-border and domestic mergers and acquisitions, spin-offs and other divestitures, restructurings, financing, and joint ventures, and he has negotiated private letter rulings with the Internal Revenue Service in the corporate, international, financial instruments, and energy tax credit areas.

• Education & Credentials

Scott earned his J.D. from American University (1997) and his B.A., cum laude with distinction, from the University of Pennsylvania (1994). He is admitted to practice in the District of Columbia (2006) and Florida (1997).

• Recognition & Leadership

Scott is a Fellow of the American College of Tax Counsel and is ranked in Chambers USA. He has been recognized in The Best Lawyers in America for Tax Law and named among Washingtonian Magazine’s Washington’s Top Lawyers (Tax). He received the Distinguished Service Award from the U.S. Department of the Treasury and was the inaugural recipient of the DC Bar’s Trailblazer Award for the Taxation Community.

• Professional Involvement

Scott is a member of the ABA Tax Section Nominating Committee and is the former Chair of the ABA Corporate Tax Committee. Within the DC Bar, he serves as Chair of the Annual Tax Legislative and Regulatory Update Conference and previously served as Chair of the Tax Section Corporate Tax Committee and as a two-term member of the Tax Section Steering Committee. He is an active author and commentator on international and corporate tax developments, including the OECD Model Tax Convention, Pillar Two, and recent U.S. tax legislation.

• Experience

Scott advises multinational companies on the tax aspects of corporate transactions, including cross-border and domestic mergers and acquisitions, spin-offs and other divestitures, restructurings, financing, and joint ventures, and he negotiates private letter rulings with the IRS in the corporate, international, financial instruments, and energy tax credit areas. Immediately prior to joining Baker McKenzie, he served as Deputy Assistant Secretary for International Tax Affairs at the U.S. Department of the Treasury through the end of the Biden Administration, leading the Office of Tax Policy’s work on international tax affairs — including regulations, treaties, and the OECD/G20 Inclusive Framework on BEPS negotiations on Pillar 1 and Pillar 2. His practice areas span Tax, Tax Disputes, Tax for M&A and Reorganizations, Tax Policy, and Financial Services Regulatory matters.

Shelley Leonard, Esq., Deputy Tax Legislative Counsel | Office of Tax Policy, US Department of the Treasury

Shelley Leonard is Deputy Tax Legislative Counsel in the U.S. Department of the Treasury’s Office of Tax Policy, where she reviews and advises on domestic tax regulations and other guidance. She previously served as Acting Assistant Secretary for Tax Policy and Acting Deputy Assistant Secretary for Tax Policy. Prior to these Treasury roles, she served as a Legislation Counsel at the Joint Committee on Taxation, where she advised on legislative and policy matters relating to tax administration and compliance, individual income tax, health, employment tax, and certain business tax credits. Earlier in her Treasury tenure, she was Deputy Tax Legislative Counsel and an Attorney-Advisor in the Office of Tax Policy, and she has also worked in private practice in the tax group of a law firm, focusing on federal tax controversy, litigation, and counseling. She began her legal career as a trial attorney for the U.S. Department of Justice, Tax Division.

• Education & Credentials

Shelley received her B.A., cum laude, from Dartmouth College and her J.D., cum laude, from Harvard Law School.

• Professional Involvement

Shelley is an active participant in the tax policy community, serving as a speaker at the D.C. Bar Tax Conference — including a panel on recent guidance on clean energy tax credits — and at the D.C. Bar Tax Legislative and Regulatory Update Conference.

• Experience

Shelley currently serves as Deputy Tax Legislative Counsel in the Treasury’s Office of Tax Policy, where she reviews and advises on domestic tax regulations and other guidance, and she has served in the acting capacities of Assistant Secretary for Tax Policy and Deputy Assistant Secretary for Tax Policy. Before her current role, she was a Legislation Counsel at the Joint Committee on Taxation, advising on legislative and policy matters relating to tax administration and compliance, individual income tax, health, employment tax, and certain business tax credits. Earlier, she served as Deputy Tax Legislative Counsel and as an Attorney-Advisor in the Office of Tax Policy, and she practiced as an associate in the tax group of a law firm in the areas of federal tax controversy, litigation, and counseling. She began her legal career as a trial attorney with the U.S. Department of Justice, Tax Division, and earlier served as a law clerk to the Honorable Michael Baylson in the U.S. District Court for the Eastern District of Pennsylvania.

Pamela Grewal, Esq., Managing Director | Andersen Tax

Pamela Grewal is a Managing Director in the US National Tax practice at Andersen, based in San Francisco. She draws on over 17 years of government experience to assist clients in navigating federal tax controversy matters. After launching her career at the Department of Justice Tax Division, she transitioned to the IRS Counsel’s National Office in Washington, D.C., where she advised IRS and DOJ personnel on emerging issues in the tax-exempt organizations sector and drafted letter rulings and regulations. Upon relocating to the San Francisco office, her legal expertise expanded significantly: she litigated cases for various divisions — including TEGEDC, LBI, SB/SE, and Strategic Litigation — and advised numerous examination teams on a wide range of issues, including Indian tribal government affairs, employment taxes, research credits, and transfer pricing.

• Education & Credentials

Pamela earned her B.A. in Economics from Pomona College and her J.D. from The University of Michigan Law School.

• Recognition & Leadership

Pamela is, a sought-after speaker on tax controversy matters, having presented at leading national programs including the Practising Law Institute’s Nuts and Bolts of Tax Controversy and its Tax Strategies conference, UCLA’s Tax Controversy Conference, the ABA Tax Section’s Criminal Tax Fraud and Tax Controversy Conference, and the ABA’s Fall Tax Meeting, and she has served as a co-chair of the NYU Tax Controversy Forum.

• Professional Involvement

Pamela is a member of the California Bar Association, the Maryland State Bar Association, the American Bar Association (Tax Section), and the Federal Bar Association, and she is admitted before the United States Tax Court. She is an active panelist and commentator on federal tax controversy developments, including agency deference following the Supreme Court’s Loper Bright decision, the Employee Retention Credit, and other enforcement priorities.

• Experience

Pamela brings more than 17 years of federal government experience to her practice. She began her career as a trial attorney at the Department of Justice Tax Division, then served in the IRS Counsel’s National Office in Washington, D.C., advising IRS and DOJ personnel on emerging tax-exempt organization issues and drafting letter rulings and regulations. After relocating to San Francisco, she litigated cases on behalf of the government for multiple divisions — including TEGEDC, LBI, SB/SE, and Strategic Litigation — and provided technical guidance to examination teams on matters such as Indian tribal government affairs, employment taxes (including worker classification and withholding), research credits, and transfer pricing. Immediately before joining Andersen, she served as a Special Trial Attorney in the IRS’s Strategic Litigation division, where she litigated complex cases of national significance on behalf of the government. She now advises clients on federal tax controversy matters in Andersen’s US National Tax practice.

Erin M. Collins, Esq., National Taxpayer Advocate | Internal Revenue Service

Erin M. Collins is the National Taxpayer Advocate, appointed to the role in March 2020 by Secretary Mnuchin. In this position she oversees the Taxpayer Advocate Service (TAS) and serves as the “Voice of the Taxpayer” within the IRS and before Congress. TAS operates as a “safety net” for taxpayers by advocating for the resolution of individual and business taxpayer issues within the IRS, and it also administers the Low Income Taxpayer Clinic federal grant program and the Taxpayer Advocacy Panel. As National Taxpayer Advocate, Erin identifies and works toward systemic changes for all taxpayers while protecting taxpayer rights, and through her Annual Report to Congress she advances administrative and legislative changes intended to protect those rights and improve the quality of taxpayer service and tax administration as an independent voice inside the IRS. She regularly testifies before the Senate Finance Committee, the U.S. House Ways and Means Committee Oversight Subcommittee, and the Senate Appropriations Subcommittee on tax administration and taxpayer rights.

• Education & Credentials

She has over 35 years of experience in tax law and previously spent 15 years in the IRS Office of Chief Counsel and 20 years at KPMG LLP.

• Recognition & Leadership

Erin has received broad recognition across the accounting and tax professions. In 2022, the American Institute of CPAs (AICPA) and CPA Practice Advisor selected her as one of the top 25 Most Powerful Women in the Accounting Profession; Accounting Today recognized her as one of the 100 Most Influential People in Accounting; and Money.com named her a Changemaker among 50 Innovators Shaping Americans’ Finances. In 2023, she received KPMG’s Fifth Annual Network of Women Alumni Legacy Award and the California Lawyers Association’s Joanne M. Garvey Lifetime Achievement Award, and Accounting Today again named her one of the 100 Most Influential People in Accounting. The UCLA Extension Tax Controversy Institute selected her to receive the Bruce I. Hochman Award in recognition of her proficiency in tax law and her leadership, and Accounting Today again recognized her on its top 100 list in 2024.

• Professional Involvement

Erin is frequently cited in national news media and tax publications and appears annually as a guest on CSPAN’s Washington Journal program. She is co-author of the Practising Law Institute’s IRS Practice and Procedure Deskbook and frequently speaks on IRS practice, procedure, controversy, and litigation matters before professional organizations and on government and tax-industry podcasts. Before joining TAS, she represented several clients pro bono to help resolve issues with the IRS and served as a volunteer and board member of the non-profit Step Up, which helps girls in under-resourced communities become confident, college-bound, and career-focused.

• Experience

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 KPMG LLP, where she retired in 2019 as the Tax Managing Director in charge of the firm’s tax controversy practice for the Western region. Throughout her KPMG career she represented thousands of individuals, partnerships, small companies, and corporate taxpayers in federal examinations, IRS appeals, and before the U.S. Tax Court on domestic and international tax issues. Since March 2020, she has served as the National Taxpayer Advocate, leading TAS and delivering the statutory Annual Report and mid-year Objectives Report to Congress.

Meghan R. Biss, Esq., Partne | Loeb & Loeb

Meghan R. Biss is a Partner at Loeb & Loeb LLP who counsels tax-exempt and nonprofit organizations at every stage of their lifecycle, advising on tax planning, compliance, and audit matters. As a former senior advisor in the Internal Revenue Service (IRS) Exempt Organizations division, she leverages over 10 years of government experience to guide clients through interactions with the IRS, the U.S. Department of the Treasury, and other government agencies. She represents a diverse array of organizations, including private foundations, national and foreign charities, social welfare organizations, colleges and universities, lobbying and political organizations, and trade associations. Meghan guides clients through applications for tax-exempt status, private letter ruling requests, and other IRS submissions; advises private foundations on excise tax issues; supports the development of compliant programmatic activities; and conducts mock audits and compliance reviews to help organizations strengthen their positions ahead of examinations. She also advises clients in tax controversy matters — including audits, investigations, and litigation involving tax-exempt status and public charity classification — and represents organizations before the U.S. Tax Court.

• Education & Credentials

Meghan earned her J.D., cum laude, from American University Washington College of Law, where she was a member of the Moot Court Honor Society and received the ABA National Appellate Advocacy Competition Award for National Best Brief. She holds a B.S. from Frostburg State University. She is admitted before the U.S. Tax Court and in the District of Columbia and Maryland.

• Recognition & Leadership

Meghan was named “Lawyer of the Year” in Nonprofit/Charities Law for Washington, D.C. by The Best Lawyers in America (2025) and has been recognized as a “Best Lawyer” in Nonprofit/Charities Law by the same publication (2024–2026). She was named in The Legal 500 US for Nonprofit and Tax Exempt Organizations (2025). During her government service, she received the Commissioner’s Award for her work on the Achieving a Better Life Experience (ABLE) Act 529A and Certified Professional Employer Organization (CPEO) Implementation Team (May 2017) and the Distinguished Service Award from Tax Exempt and Government Entities (January 2018). In 2026, she was elected a Fellow of the American College of Tax Counsel.

• Professional Involvement

Meghan serves as Vice Chair of the Exempt Organizations Committee of the American Bar Association Section of Taxation, and was formerly Vice Chair for Legislative Developments within that committee. She is an Associate Member of the Exempt Organizations Technical Resource Panel of the American Institute of Certified Public Accountants (AICPA) and a member of the American Bar Association. A frequent speaker at national industry institutes, seminars, and conferences on legal issues affecting nonprofits and tax-exempt organizations, her recent engagements include the AICPA Not-for-Profit Industry Conference, Georgetown Law’s Conference on Representing & Managing Tax-Exempt Organizations, the TEGE Annual Exempt Organizations Update and Meeting, the DC Bar’s Annual Tax Conference, and Clark Nuber’s Western Philanthropy Conference.

• Experience

Meghan brings more than 10 years of IRS experience to her practice. During her time at the IRS, she served as senior technical advisor to the director of exempt organizations, advising on all matters related to nonprofits and tax-exempt organizations — including overhauling the application process and enhancing the data-driven approach to examinations — and collaborating with the IRS Chief Counsel and the Treasury Department on the development of regulations and guidance on donor-advised funds, supporting organizations, and political campaign intervention activities. She worked closely with the IRS Division Counsel and the U.S. Department of Justice on exempt organization litigation. Prior to that role, she addressed a wide range of public-sector issues including disaster relief, unrelated business income tax (UBIT), excess benefit transactions, charter and private schools, and environmental concerns. As a Presidential Management Fellow, she served as a special attorney in the Civil Appellate Section of the Tax Division at the Department of Justice, handling a variety of appellate tax litigation issues. She joined Loeb & Loeb as a partner in its Nonprofits and Tax-Exempt Organizations practice in 2024.

Susanne Sachsman Grooms, Esq., Partner | Cooley

Susanne Sachsman Grooms is a Partner at Cooley LLP, where she leads the firm’s bipartisan congressional investigations practice. A former federal prosecutor and one of the nation’s leaders in congressional investigations, her practice focuses on helping clients navigate high-stakes, complex investigations that potentially involve multiple federal and state agencies, Congress, and regulatory authorities, as well as significant reputational concerns. Her record of leading hundreds of congressional investigations from inside the government gives her a leading edge in assisting clients with congressional investigations, other government and regulatory investigations, internal investigations, and crisis management. She provides counsel and advice in support of and during matters before Congress, having assisted clients in front of investigatory committees and in responding to individual member requests in both the House and Senate, and she has prepared numerous company executives for public testimony in inquiries around the globe.

• Education & Credentials

Susanne earned her J.D. from Harvard Law School and her B.A., cum laude, from Yale University. She is admitted to practice in New York and the District of Columbia.

• Recognition & Leadership

Susanne is ranked by Chambers USA in Band 1 for Government Relations: Congressional Investigations — Nationwide (2023–2025) and was named to Lawdragon’s 500 Leading Litigators in America (2026). She is recognized in The Legal 500 US for Corporate Investigations and White-Collar Criminal Defense (2025), as a Future Star by Benchmark Litigation, among the Most Influential People in Washington by Washingtonian magazine, and among Lawdragon’s 500 Leading Plaintiff Employment & Civil Rights Lawyers. During her government service she received the Tax Division Outstanding Attorney Award (2005) and the Tax Division Special Act or Service Award (2006) from the U.S. Department of Justice.

• Professional Involvement

Susanne teaches Congressional Investigations at the Georgetown University Law Center and is a frequent speaker on matters related to congressional oversight and investigations. She has been an invited speaker at events organized by the American Bar Association, the New York City Bar Association, the University of Pittsburgh Institute of Politics, and the Dick Thornburgh Forum for Law and Public Policy, and she serves on Law360’s Massachusetts editorial advisory board (2025).

• Experience

Susanne began her career as a trial attorney in the Tax Division of the U.S. Department of Justice, where she was a member of the Attorney General’s Honors Program. From 2008 to 2010, she served in a number of roles at the Internal Revenue Service, including as attorney adviser to the deputy commissioner for services and enforcement and as senior counsel to the chief of criminal investigation. In 2010, she was detailed to the White House, where she served as deputy associate counsel in the Office of Presidential Personnel, vetting presidential appointments and nominations and advising on tax compliance and other legal matters. She joined the U.S. House Committee on Oversight and Government Reform — the principal investigative committee of the U.S. House of Representatives — as counsel under Chairman Henry A. Waxman, and advanced into senior leadership, supervising and conducting hundreds of congressional hearings and investigations and leading the committee’s investigative staff from 2011 to 2021. As deputy staff director and chief counsel for then-Chairwoman Carolyn Maloney and her predecessor Chairman Elijah E. Cummings, she oversaw a team of more than 70 attorneys, investigators, and communications and support staff on hundreds of high-profile investigations, and she served on the investigatory and Senate trial teams for both impeachments of Donald J. Trump. Since February 2024, she has led Cooley’s congressional investigations practice, where her representations include advising Fortune 500 companies, financial institutions, universities, media organizations, and senior executives in connection with investigations and public testimony before congressional committees in the U.S. and abroad.

Casey A. Lothamer, Esq., Senior Counsel | Loeb & Loeb

Casey A. Lothamer is Senior Counsel at Loeb & Loeb LLP in Washington, DC, where he advises nonprofits and tax-exempt organizations across the full spectrum of federal tax and regulatory matters, ranging from organizational structuring and tax-exemption issues to governance, compliance, IRS controversy and operational matters. Drawing on nearly 20 years of experience within the IRS Tax Exempt & Government Entities Division Counsel (TEGEDC), he guides clients through IRS examinations, determinations, compliance matters, audits, investigations and tax controversy proceedings. Casey advises public charities, private foundations, social welfare organizations and international nonprofits with U.S. affiliates on governance, operational structuring and compliance with federal tax requirements applicable to exempt organizations. He assists with tax-exempt status applications, private letter ruling requests and other agency submissions, as well as excise tax matters affecting private foundations and the implementation of compliant charitable programs. He also conducts mock audits and compliance assessments to help organizations identify potential issues and strengthen their preparedness ahead of examinations, represents clients in tax controversy and enforcement matters — including matters before the U.S. Tax Court — and counsels clients on regulatory developments affecting exempt organizations while engaging with government officials on Treasury regulations and IRS guidance.

• Education & Credentials

Casey earned an LL.M. in Taxation from Georgetown University Law Center and his J.D. from the University of Pittsburgh School of Law, where he served as Founder and Executive Editor of the Pittsburgh Tax Review. He holds a B.S. from the University of Central Florida. He is admitted to practice before the U.S. Supreme Court and the U.S. Tax Court and is admitted only in Maryland.

• Recognition & Leadership

Casey served as a Former Adjunct Professor at the University of Baltimore School of Law from 2024 to 2025.

• Experience

Before joining Loeb, Casey served for nearly two decades across a progression of senior roles within the TEGEDC of the Office of Chief Counsel at the IRS, including as senior level counsel and area counsel, where he was instrumental in shaping and advancing the IRS’ legal positions on complex exempt organization matters. While at the TEGEDC, he led and supervised significant, high-stakes litigation at both the trial and appellate levels and served as the primary technical authority for exempt organization issues within his branch. He played a central role in reviewing, approving and issuing guidance on the federal tax treatment of sophisticated transactions involving tax-exempt entities, including regulations with nationwide impact, and oversaw technical advice provided to both the public and the IRS. He also reviewed defense submissions to the U.S. Department of Justice in declaratory judgment actions brought by tax-exempt organizations.

Abbey Garber, Esq., Partner | Holland & Knight

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

• Education & Credentials

Mr. Garber earned his J.D. from The University of Texas School of Law and his B.B.A. from The University of Texas at Austin. He is admitted to practice in Texas, and before the U.S. Court of Federal Claims, the U.S. District Courts for the Western and Northern Districts of Texas, and the U.S. Tax Court.

• Recognition & Leadership

Mr. Garber has been recognized in The Best Lawyers in America guide for Tax Law (2020–2026) and Litigation and Controversy – Tax (2024–2026), and was named the Dallas Litigation and Controversy – Tax “Lawyer of the Year” (2026). He has been listed among the Best Lawyers in Dallas by D Magazine for Tax: Litigation (2019, 2023–2026) and named among Leading Global Tax Lawyers by Lawdragon 500 (2025). He was named the 2024 Outstanding Texas Tax Lawyer by the State Bar of Texas, Tax Section, and has been recognized by The Legal 500 USA for Tax: U.S. Taxes: Contentious (2019, 2021–2024). During his government service, he received the National Outstanding Instructor Award from the IRS Office of Chief Counsel (2008), Manager of the Year for the IRS Office of Chief Counsel (Small Business/Self Employed) (2007), and the Public Service Excellence Award from the Dallas-Fort Worth Federal Executive Board (2003). He is a Fellow of the Texas Bar Foundation (2020–present) and the American College of Tax Counsel (2019–present).

• Professional Involvement

Mr. Garber is a member of the Dallas Bar Association, Tax Section (2018–present), and the American Bar Association, Tax Section (Administrative Practice Committee and Court Practice and Procedure Committee). Within the State Bar of Texas, Tax Section, he serves as Chair-Elect (2025–2026), having previously served as Secretary (2024–2025), Treasurer (2023–2024), Council Member (2019–2023), CLE Co-Chair (2020–2023), IRS Representative (2004–2018), and in Law School Outreach (2008–2019). He has served as Course Director for the State Bar of Texas Advanced Tax Law Course (2008, 2020, and 2022) and on its Planning Committee (2007–2024). He is a frequent speaker on tax topics, including IRS appeals updates and surviving IRS partnership audits, and has been engaged multiple times as an expert witness in courts throughout the country on tax law and IRS procedure.

• Experience

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 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. He also served as the Southwest Area Team Leader in Chief Counsel, charged with ensuring collaboration and cooperation across operating divisions in a ninestate area. In private practice, his representative matters include representing several small businesses in audits of the Employee Retention Credit, including settling a multimillion-dollar credit claim for an Austin credit union; representing a foreign airline in the favorable resolution of an asserted multimillion-dollar tax liability with no additional tax due; appealing an IRS deficiency in excess of $20 million against a California homebuilder and resolving it with a refund without litigation; settling a U.S. Tax Court case for a Texas-based restaurant company for no deficiency after the IRS asserted more than $10 million in tax and penalties; obtaining a multimillion-dollar settlement in a professional malpractice action against an accounting firm; settling estate and gift tax and payroll tax cases on favorable terms; assisting Holland & Knight’s White Collar Defense and Investigations Team in resolving proposed criminal tax matters without prosecution; and serving as an expert witness on tax law and IRS procedure.

Niles A. Elber, Esq., Member | Caplin & Drysdale, Chartered

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. He is particularly focused these days on defending clients who find themselves caught up in aggressive IRS campaigns against alleged abusive tax shelters and transactions, and he most recently represented a defendant in one of the largest and most significant tax cases brought by the U.S. Department of Justice in the “conservation easement” area.

• Education & Credentials

Mr. Elber earned his LL.M. from New York University School of Law (1999), his J.D., cum laude, from Tulane University Law School (1998), and his B.S. from the University of North Carolina at Charlotte (1993). He is admitted in the District of Columbia and North Carolina, and before the U.S. Supreme Court, the U.S. District Court for the Western District of North Carolina, the U.S. Tax Court, the District of Columbia Court of Appeals, and the U.S. District Court for the District of Columbia.

• Recognition & Leadership

Mr. Elber is a Fellow of the American College of Tax Counsel (ACTC), an honor reserved for those at the top of their profession, and a Fellow of the American Bar Foundation. He is a former ABA Nolan Fellow, which honors a select group of outstanding young tax lawyers from across the nation. He has been recognized by Chambers USA (2025–present); by The Legal 500 as a Next Generation Lawyer (2017–2022), Recommended (2017–present), and Leading Lawyer (2023–present); by Super Lawyers, Washington, D.C. (2020–present); by The Best Lawyers in America (2025); and is Martindale-Hubbell AV Preeminent rated. He was also named a Leading Global Tax Lawyer by Lawdragon (2025).

• Professional Involvement

Mr. Elber is a member of the American Bar Association, Section of Taxation, and is a past chair of its Civil and Criminal Tax Penalties Committee, serving from 2017 until 2019 after serving as a vice-chair on the same committee for five years. He co-authored the BNA Portfolio Report of Foreign Bank and Financial Accounts (FBAR) and lectures regularly on matters involving tax controversies. His recent speaking engagements include presentations on IRS administrative summonses and government subpoenas and John Doe summonses at the NYU Tax Controversy Forum, criminal tax enforcement at the ABA White Collar Crime Institute, and conservation easements at the ABA Criminal Tax Fraud and Tax Controversy Conference. He is also a frequent media commentator on IRS enforcement, FBAR, conservation easements, and the Corporate Transparency Act for outlets including Tax Notes, Bloomberg Law, and Law360.

• Experience

Mr. Elber represents clients across the full range of civil and criminal tax controversy matters, including IRS examinations, Appeals matters, collections, and proceedings in federal court, as well as administrative and grand jury tax investigations on the criminal side. He has considerable experience in offshore compliance matters, having assisted hundreds of clients with voluntary disclosures and income tax and FBAR penalty exams related to unreported foreign bank accounts. He is currently focused on defending clients caught up in aggressive IRS campaigns against alleged abusive tax shelters and transactions, and most recently represented a defendant in one of the largest and most significant tax cases brought by the U.S. Department of Justice in the conservation easement area.

Guinevere M. Moore, Esq., Managing Member | Moore Tax Law Group

Guinevere Moore represents taxpayers in significant disputes with the Internal Revenue Service, the Department of Justice, Tax Division, and state taxing agencies. She is the Managing Member of Moore Tax Law Group, LLC, a tax controversy and tax litigation firm with an office in Chicago. Guinevere has over fifteen years of experience helping taxpayers resolve significant disputes with the IRS and state tax agencies, and she routinely represents taxpayers in highstakes criminal and civil tax disputes. She takes a holistic approach to representing clients, getting to know each client and developing a deep understanding of their needs and preferences before developing a strategy for the case. She is also a frequent speaker and author, routinely publishing articles and speaking at conferences around the world on tax controversy and tax litigation, including in Forbes, Bloomberg, and Tax Notes.

• Education & Credentials

Guinevere earned her J.D., cum laude, from DePaul University College of Law (2008) and her B.A., with Highest Honors, from DePaul University (2003). She is admitted before the Supreme Court of Illinois, the U.S. Tax Court, the U.S. Court of Federal Claims, the Supreme Court of the United States, the U.S. Courts of Appeals for the First, Third, Sixth, Seventh, Eighth, Ninth, Tenth, Eleventh, D.C., and Federal Circuits, and numerous U.S. District Courts, including the Northern and Central Districts of Illinois (Northern District Trial Bar), the Western District of New York, the Eastern and Western Districts of Wisconsin, and the Eastern District of Missouri.

• Recognition & Leadership

Guinevere is a Fellow of the American College of Tax Counsel (ACTC). She received the 2024 Janet Spragens Pro Bono Award from the American Bar Association and the Nolan Fellowship from the ABA Section of Taxation. She has been recognized by ITR World Tax as a Highly Regarded Practitioner for U.S. Tax Controversy (2022–2025); by Chambers USA for Tax: Controversy (2023–2024, Band 3); by the Chambers High Net Worth Guide for Tax: Private Client (2022–2023, Band 2); and by The Best Lawyers in America (2023–2025). She was named among America’s Top 100 Criminal Defense Attorneys for Illinois (2022), among Chicago’s Notable Women Lawyers by Crain’s, and a Rising Star by Illinois Super Lawyers Magazine, and she has received the Volunteer Champion Award from the Center for Economic Progress and Volunteer of the Year from Ladder Up.

• Professional Involvement

Guinevere is an active member of the tax bar and of the American Bar Association, Section of Taxation, where she currently serves on Council and has previously served as chair of the Standards of Tax Practice Committee, helping design and implement continuing education seminars for attorneys and tax professionals focusing on civil and criminal tax disputes and tax ethics. She is a regular tax contributor to Forbes and a prolific author in Tax Notes, Bloomberg Tax, the Journal of Tax Practice & Procedure, The Tax Adviser, and ABA Tax Times, writing on topics including the Employee Retention Credit, BBA partnership audits, cryptocurrency enforcement, conservation easements, voluntary disclosure, and tax ethics. She is a frequent national speaker before the ABA, the NYU Tax Controversy Forum, the UCLA Extension Tax Controversy Institute, the IRS Nationwide Tax Forum, PLI, and CPA societies, and serves on the Chicago Board of Directors of the March of Dimes.

• Experience

Guinevere represents taxpayers in significant civil tax disputes of all kinds—assessable penalties, income, estate, gift, payroll, excise, and sales tax—and has resolved disputes on behalf of individuals, partnerships, corporations, trusts, and estates, both at the examination level and at IRS Appeals. When agreement cannot be reached, she has significant litigation experience, acting as lead counsel for taxpayers in the United States Tax Court, Federal District Court, and the Court of Federal Claims, as well as in Courts of Appeal around the country, including the Seventh, Eleventh, and D.C. Circuits, and has litigated on behalf of taxpayers as amicus curiae in the Supreme Court of the United States, twice leading to taxpayerfavorable outcomes. In recent years, she has increased her representation of clients in valuation matters, including representing appraisers and taxpayers defending valuations and defending clients against penalties associated with appraisals under Treasury Regulations. On the criminal side, Guinevere and the Moore Tax Law Group team represent clients in federal criminal tax investigations and white collar cases across the country, working to resolve cases without formal charges where possible; when charges cannot be avoided, she works to craft creative plea and sentencing agreements or, when appropriate, to proceed to trial—securing a complete acquittal in the summer of 2023 after a twelve-week jury trial in the Northern District of Georgia as lead counsel. She also maintains a strong pro bono practice, with representative Tax Court matters including Hughes v. Commissioner, Thompson v. Commissioner, and Pryor v. Commissioner, and amicus work for the Center for Taxpayer Rights and the American College of Tax Counsel in cases including Bittner v. United States and Marinello v. United States.

Jared E. Dwyer, Esq., Founding Shareholder | Dwyer Law PA

Jed Dwyer is a trial lawyer who focuses his practice on criminal and civil tax litigation, white collar criminal defense matters, and complex civil litigation, at his boutique trial firm Dwyer Law, P.A. in Miami. Jed has tried more than 40 jury and non-jury trials and has been involved in over 100 investigations, many of which included complex fraud and regulatory matters. A proven strategic thinker with significant trial and investigative experience, Jed is routinely called on to represent individuals and companies in their most important matters, both criminal and civil, including proceedings concerning tax fraud, money laundering, corruption, health care fraud, False Claims Act matters, and civil fraud.

• Education & Credentials

He is admitted to practice in Connecticut and Florida, joined the U.S. Department of Justice through the Attorney General’s Honors Program, and practices from the firm’s Miami office.

• Recognition & Leadership

Jed has been recognized as a Best Lawyer in America for Criminal Defense: White-Collar and ranked in the Chambers USA Guide for Litigation: White Collar Crime & Government Investigations (Florida), and named to Lawdragon’s “500 Leading Litigators in America.” His trial work has been described by adversaries as “exceptional” and “skilled,” and The Legal 500 reported an observer’s description of Jed as an outstanding courtroom lawyer and exceptional cross-examiner, while the Chambers USA Guide has described him as creative, hard-working, and relentless. Prior to founding the firm, Jed served as Chair of the Global White Collar and Investigations group of a global Am Law 20 law firm of over 2,500 lawyers, and as Co-Chair of that firm’s Miami litigation group, helping lead one of the largest and most sophisticated white collar litigation practices in the world.

• Professional Involvement

In his prior firm leadership roles, Jed guided case strategy and served as a key advisor on the firm’s most sensitive and high-stakes litigation, driving results across a global practice—experience that now informs Dwyer Law’s focused, boutique approach.

• Experience

Before entering private practice, Jed served ten years as a federal prosecutor—first as a trial attorney with the U.S. Department of Justice, Criminal Enforcement Section, Tax Division, which he joined through the Attorney General’s Honors Program, and then as an Assistant United States Attorney at the U.S. Attorney’s Office for the Southern District of Florida. At the Tax Division, he handled all aspects of complex tax fraud investigations and prosecutions in districts throughout the country. As an Assistant United States Attorney, he concentrated on the investigation and trial of white collar crimes, including mail and wire fraud, public corruption, money laundering, and Bank Secrecy Act violations, routinely working closely with FinCEN, the OCC, and the IRS in criminal and regulatory matters involving financial institutions. Today, he leverages this experience to represent individuals and organizations in complex investigations and proceedings concerning tax fraud, money laundering, corruption, health care fraud, False Claims Act matters, and civil fraud, among others.

Tino M. Lisella, Esq., Shareholder | Carlton Fields

Tino Lisella is a Shareholder at Carlton Fields, based in West Palm Beach, and a former FINRA enforcement director and former federal tax prosecutor. Tino’s practice focuses on securities enforcement, civil and criminal tax controversy, and white collar litigation. He represents individuals and entities in complex securities matters and government investigations, as well as regulatory investigations and enforcement, and brings firsthand knowledge of the bootson-the-ground strategies and priorities that prosecutors and FINRA enforcement attorneys use to build their cases—and the most effective strategies to defend against them. Tino also has significant experience in matters involving vulnerable adults and elderly customers.

• Education & Credentials

Tino earned his J.D., magna cum laude, from Stetson University College of Law (2007), where he served as an editor of the Stetson Law Review, and holds a Master of Accounting (2003) and a B.S., magna cum laude (2002), both from Florida State University. He is admitted to practice in Florida and New Jersey, and before the U.S. Court of Federal Claims and the U.S. District Court for the Middle District of Florida. Earlier in his career, he was a certified public accountant.

• Recognition & Leadership

Tino was elected to Shareholder at Carlton Fields in 2025. During his government service, he served as Assistant Chief of the U.S. Department of Justice’s Criminal Tax Division and as a Director and Principal Counsel in FINRA’s Department of Enforcement, and he is frequently quoted as an authority on tax and securities enforcement in outlets including Law360, Financial Planning, USA Today, and the Federal News Network.

• Professional Involvement

Tino is an active author and speaker on tax controversy and securities enforcement topics. His publications address the IRS Voluntary Disclosure Program and FINRA’s annual regulatory oversight reports, among other subjects, and his recent speaking engagements include “How Not to Be a Witness Against Your Client: Ethical and Other Considerations in Criminal Tax Investigations” at the 2024 ABA Criminal Tax Fraud and Tax Controversy Conference, “Proving the Case: How to Defend a Deposits Case” at the ABA 40th Annual National Institute on Criminal Tax Fraud (2023), and FINRA enforcement and fraud-update panels for the American Bar Association and the ACLI.

• Experience

Before entering private practice, Tino spent nearly a decade at the U.S. Department of Justice, Tax Division, and more than five years at FINRA. At FINRA (2017–2022), he served as a Director (2018–2022) and Principal Counsel (2017–2018) in the Department of Enforcement, responsible for supervising investigations involving sales practice violations of complex products—including syndicated conservation easements, variable annuities, and leveraged and inverse exchange-traded funds—and large-scale investigations involving anti-money laundering violations. At the DOJ (2007–2017), he served as a Trial Attorney (2007–2014), Counsel to the Assistant Attorney General of the Tax Division (2013–2014), Special Assistant U.S. Attorney for the Southern District of New York (2012–2017), and ultimately Assistant Chief of the Criminal Tax Division (2015–2017), where he led high-profile investigations and federal criminal tax prosecutions, including the prosecution of California businessman Masud Sarshar, who concealed more than $23.5 million in undeclared Israeli bank accounts. Earlier in his career, Tino was a certified public accountant and tax consultant with a Big Four accounting firm.

Rod J. Rosenstein, Esq., Partner | Baker & McKenzie

Rod Rosenstein is a member of the North America Litigation & Government Enforcement Practice Group and the Global Dispute Resolution Practice Group, based in Baker McKenzie’s Washington, DC office. He is co-chair of the firm’s National Security Practice, a team of former US government officials, former prosecutors, trade practitioners, and data privacy and cyber lawyers. During the administrations of Presidents George W. Bush, Barack Obama, and Donald Trump, Rod held senior political appointments as the Deputy Attorney General of the United States, US Attorney for the District of Maryland, and Principal Deputy Assistant Attorney General for tax enforcement in the US Department of Justice. He previously served as an Assistant US Attorney and a Criminal Division trial attorney, and represented the US government in 23 jury trials while arguing 21 civil and criminal cases in appellate courts and the US Supreme Court. He also served as a law clerk to Judge Douglas Ginsburg of the US Court of Appeals for the District of Columbia Circuit. As the second-highest ranking Department of Justice official, Rod managed a USD 28 billion budget and oversaw 115,000 employees in the Department’s litigating divisions, law enforcement agencies, and US Attorney’s Offices.

• Education & Credentials

Rod earned his J.D., cum laude, from Harvard Law School (1989) and his B.S., summa cum laude, from the University of Pennsylvania Wharton School (1986). He is admitted in Pennsylvania, the District of Columbia, and Maryland, and before the U.S. Supreme Court, the U.S. Tax Court, the U.S. Courts of Appeals for the First, Fourth, Fifth, and D.C. Circuits, and the U.S. District Courts for the District of Maryland and the District of Columbia.

• Recognition & Leadership

Rod is recognized by Chambers for Litigation: White-Collar Crime & Government Investigations and by Benchmark Litigation for Washington, DC White Collar Crime. His honors include the Chief’s Award from the Metropolitan Police Department (2021), the Public Servant Award from the Armenian Bar Association (2019), the Distinguished Service Award from the Maryland State’s Attorneys’ Association (2017), the Courage in Government Award from the Greater Baltimore Committee (2017), the J. Joseph Curran Public Service Award from the Maryland Bar Foundation (2017), Fraud Fighter of the Year from the Association of Certified Fraud Examiners (2009), the Traphagen Distinguished Alumnus award from Harvard Law School (2006), the Chief’s Award from the IRS Criminal Investigation Division (2005), and a Wasserstein Public Interest Fellowship from Harvard Law School (1997). In senior DOJ leadership, he developed policies concerning corporate criminal prosecutions and parallel domestic and foreign investigations, FCPA matters, and health care fraud cases, led the Cyber-Digital Task Force and the Task Force on Market Integrity and Consumer Fraud, and reviewed national security issues as a member of the Committee on Foreign Investment in the United States (CFIUS).

• Professional Involvement

Rod is a member of the American Bar Association, the American Law Institute, the American Bar Foundation, the American College of Tax Counsel, the Federal Bar Association, the Maryland State Bar Association, the National Association of Former US Attorneys, the Legal Services Corporation, the Edward Bennett Williams Inn of Court, the Lawyers’ Round Table Law Club of Baltimore, the Serjeants’ Inn Law Club of Baltimore, the Harvard Law School Alumni Association, and the Wharton Club of DC. He is an active author and speaker, with recent publications in Bloomberg Law, Law360, and JD Supra on criminal enforcement trends, FARA, and DOJ policy, and recent speaking engagements before the American Bar Association, the New York City Bar Association, the American Academy of Attorney-CPAs, and law schools on federal enforcement, criminal tax enforcement, and the rule of law.

• Experience

Rod is a highly skilled trial and appellate lawyer with more than three decades of experience resolving complex civil and criminal matters and representing companies and universities in federal and state enforcement investigations and congressional investigations. He advises clients facing sensitive regulatory, enforcement, and litigation challenges, including government investigations, crisis management, national security and cybersecurity issues, tax controversies, internal investigations, compliance, and monitoring. His recent matters include representing a university in a congressional investigation; representing companies in federal investigations of potential criminal antitrust, tax, Foreign Corrupt Practices Act, and Foreign Agents Registration Act violations; representing a defendant charged with conspiring to evade US sanctions; representing an individual in a federal money laundering investigation; representing a defendant in a federal False Claims Act lawsuit; representing a corporate executive and a law firm in federal investigations of potential criminal tax violations; and representing companies in federal tax audits and civil litigation. As Deputy Attorney General, he approved significant proposed criminal and civil enforcement actions, False Claims Act settlements, and corporate monitor appointments.

Carlos F. Ortiz, Esq., Partner | BakerHostetler

Carlos F. Ortiz is a Partner at BakerHostetler, based in the firm’s New York office. A seasoned trial attorney, recognized by Law360 as a “Legal Lion of the Week” and by AmLaw’s Litigation Daily as a “Litigator of the Week,” Carlos focuses his practice on high-risk tax controversies, anti-corruption (Foreign Corrupt Practices Act (FCPA) and Foreign Extortion Protection Act (FEPA)), 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, and on several occasions has prevented the referral of charges for the target of criminal tax investigations.

• Education & Credentials

Carlos earned his LL.M. from the University of Baltimore School of Law and his J.D. from Brooklyn Law School. He is admitted to practice in New York and New Jersey. (His firm’s public bio does not list his bar admissions in the text available; the New York office and his prior New Jersey government service are confirmed by firm and news sources.) • Recognition & Leadership Carlos has been recognized by Law360 as a “Legal Lion of the Week” and by AmLaw’s Litigation Daily as a “Litigator of the Week,” and is ranked by Chambers USA, which has described his white-collar defense practice as demonstrating strength across a range of criminal tax proceedings and investigations and characterized him as a leading, go-to practitioner in the tax defense area. Before private practice, he served as Acting Chief of the Criminal Division at the U.S. Attorney’s Office in New Jersey and previously chaired Blank Rome’s white-collar defense team.

• Professional Involvement

Carlos is an active author and speaker on criminal tax enforcement, cryptocurrency, and white-collar topics, frequently co-authoring client alerts and articles with BakerHostetler colleagues on IRS criminal investigations, virtual currency enforcement, and DOJ priorities. He has advised corporations, their boards of directors, and their committees in connection with corporate governance and compliance matters.

• Experience

Carlos brings a roughly 15-year background as a federal prosecutor to his practice. He served as a trial attorney with the U.S. Department of Justice, Tax Division, in Washington, and as an Assistant United States Attorney, including as Acting Chief of the Criminal Division at the U.S. Attorney’s Office in New Jersey, and earlier served as a U.S. Army JAG officer. In private practice, he has represented individuals and corporations in numerous criminal tax investigations, including a large accounting firm and several investors in tax shelter prosecutions brought in the Southern District of New York; represented the target of a criminal tax and money laundering grand jury investigation, resulting in the declination of charges by the U.S. Attorney’s Office for the Southern District of Florida; and represented a pharmacist involved in a multiyear, multimillion-dollar tax evasion scheme prosecuted by the Manhattan District Attorney’s Office, resulting in a probation sentence and no civil fraud penalty. He has also secured the dismissal of a superseding indictment one month before trial.

Sara G. Neill, Esq., Shareholder | Neill Schwerin Boxerman, PC

Sara Neill is a Shareholder at Neill Schwerin Boxerman, P.C. in St. Louis, where she focuses her practice on representing clients with serious civil and criminal tax problems. Her success as an attorney is attributable to her dedication to her clients and desire to obtain the best possible results for them, a great deal of hard work, and her deep experience and knowledge of the federal tax system. Sara regularly represents individual and business clients in matters such as audits, administrative appeals, and litigation, and advises clients with sensitive tax problems, such as those who have failed to file returns, underreported income, neglected to remit trust fund or other employment taxes, or failed to pay significant amounts of tax due. She frequently represents clients in IRS criminal tax investigations and litigation, has defended numerous lawyers, accountants, and other tax professionals in IRS preparer/promoter penalty investigations and appeals as well as in criminal tax cases, and advises tax professionals on matters involving Circular 230 and on ethics and disciplinary matters before their professional licensing boards.

• Education & Credentials

Sara earned her LL.M. in Taxation from Washington University (2015), her J.D. from the University of Missouri—Columbia (2003), and her B.S. in Business Administration, with honors, from the University of Missouri—Columbia (1999). She is admitted to practice in Missouri and Illinois, and before the U.S. District Courts for the Eastern and Western Districts of Missouri and the District of Colorado, as well as the U.S. Tax Court.

• Recognition & Leadership

Sara is a Fellow of the American College of Tax Counsel. She has been named “Lawyer of the Year” for Litigation and Controversy–Tax (St. Louis) by The Best Lawyers in America (2015, 2018, and 2025) and listed in The Best Lawyers in America for Litigation and Controversy–Tax and Criminal Defense: White Collar (St. Louis) since 2015. She has been recognized among the “Top 50: St. Louis Super Lawyers” (2022 and 2023) and “Top 50: Women Missouri and Kansas Super Lawyers” (2022), and has appeared on the Super Lawyers Missouri and Kansas list for Tax Law since 2015. Missouri Lawyers Weekly named her to its “Top 100 POWER List” (2022) and “The POWER List—Tax” (2021, 2022, and 2025), and honored her with a “Women’s Justice Award – Business Practitioner” (2016) and “Up and Coming – Law Firm Leader” recognition (2014). She also received the “President’s Award” from the Bar Association of Metropolitan St. Louis (2014) and was appointed by the Missouri Bar Board of Governors to the Study Commission on State Tax Policy.

• Professional Involvement

Sara is actively involved in local and national bar associations. She recently served as President of the Bar Association of Metropolitan St. Louis and currently serves as Chair of its Governance Committee, having previously served as its Tax Section Chair. She regularly attends and lectures at meetings of the American Bar Association’s Section of Taxation and currently serves as a Vice-Chair of its Civil and Criminal Tax Penalties Committee, and she recently completed a five-year term on the Section’s Appointments to the Tax Court Committee. She is also a member of the Women in White Collar Defense Association, the Federal Bar Association, the Women Lawyers’ Association of Greater St. Louis, the St. Louis Lawyers Association, the St. Louis County Bar Association, and the Missouri Bar. As an adjunct professor of law in Washington University Law School’s Tax LL.M. program, Sara co-teaches courses on “Federal Tax Procedure” and “Tax Fraud Investigations and Prosecutions,” and she routinely lectures to law students in the Low-Income Taxpayer Clinic while joining them in providing pro bono legal services to taxpayers with U.S. Tax Court matters. In the community, she serves on the Boards of Directors of The Bar Plan Mutual Insurance Company, the St. Louis Bar Foundation, the Missouri Lawyer Trust Account Foundation, and the University of Missouri Law School Foundation. She is a frequent national speaker and an author whose work has appeared in the St. Louis Bar Journal and the Journal of Passthrough Entities.

• Experience

Sara represents individuals and businesses across the full range of civil and criminal federal tax matters, including audits, administrative appeals, U.S. Tax Court and other litigation, IRS criminal tax investigations, and preparer/promoter penalty matters. Her representative criminal tax matters include persuading the Department of Justice to close or decline prosecution in numerous tax evasion and § 7206(2) investigations of business owners, accountants, and return preparers; negotiating favorable plea agreements resulting in probation or home-confinement sentences; and using the IRS’s Expedited Plea Program to mitigate sentencing exposure. Her representative civil tax matters include successfully challenging IRS Notices of Deficiency alleging millions of dollars in deficiencies at trial before the U.S. Tax Court (with the court holding completely for her clients and ordering the IRS to pay attorneys’ fees); obtaining innocent spouse relief under 26 U.S.C. § 6015 avoiding liabilities exceeding $7 million, $2 million, and $200,000 in separate matters; persuading the IRS to concede civil fraud penalties under § 6663 and preparer penalties under §§ 6694(b), 6700, and 6701; and abating substantial penalties for reasonable cause and information-reporting failures.

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

Larry Campagna is a Shareholder at Chamberlain Hrdlicka, based in the firm’s Houston office, with an established reputation as an authoritative litigator in matters of business litigation, white-collar criminal defense, and particularly in 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 his 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. He also teaches a course in the law of Tax Crimes and Money Laundering as an Adjunct Professor at the University of Houston Law Center.

• Education & Credentials

Larry earned his B.A. (1974) and his J.D. (1977), both from the University of Texas at Austin. He is admitted to practice in Texas, and before the United States Supreme Court, the Supreme Court of Texas, the U.S. Courts of Appeals for the Fifth, Ninth, Eleventh, and Federal Circuits, the U.S. Court of Federal Claims, the United States Tax Court, and the U.S. District Courts for the Southern, Northern, Eastern, and Western Districts of Texas.

• Recognition & Leadership

Larry was unanimously inducted as a Fellow of the American College of Tax Counsel (1995) and currently serves as a member of its Board of Regents. He has been listed in The Best Lawyers in America for Litigation and Controversy–Tax (2011–2026), Tax Law (2010, 2019–2026), and Criminal Defense: White-Collar (2019–2026), and was named Best Lawyers’ Litigation & Controversy–Tax “Lawyer of the Year” in Houston (2014, 2016, and 2025). He is ranked in Chambers USA for Tax: Fraud (Nationwide, Band 1, 2008–2026) and Texas Tax: Litigation (Band 1, 2011–2026), and in Chambers High Net Worth for Tax: Private Client (Nationwide, Band 1, 2023–2025). He has been named to The Legal 500 Hall of Fame for U.S. Taxes: Contentious (2022, 2025), the Lawdragon 500 Leading Global Tax Lawyers (2025), and Texas Super Lawyers for Tax (2003–2025). His other honors include the Jules Ritholz Memorial Merit Award from the ABA Tax Section’s Civil and Criminal Tax Penalties Committee (2022), recognition as a “Texas Tax Legend” by the State Bar of Texas (2019), the Bruce I. Hochman Award at the UCLA Tax Controversy Institute (2020), and “Most Admired CEOs” by the Houston Business Journal (2021).

• Professional Involvement

Larry served as President of the American College of Tax Counsel for the 2023–2024 year and sits on its Board of Regents, having also served as Vice President, Secretary-Treasurer, and Chair of its Nominations Committee. Within the American Bar Association Section of Taxation, he has served as Vice-Chair for Administration, Chair and Vice-Chair of the Committee on Civil and Criminal Tax Penalties, Chair of the Task Force on Offshore Credit Card Cases, Chair of the Subcommittee on IRS Investigations and Procedures, Chair and Vice-Chair of the Committee on Employment Taxes, and Liaison to Standards of Tax Practice. He is a member of the College of the State Bar of Texas and serves on the Advisory Board of Editors of the CCH Journal of Tax Practice and Procedure. A prolific author and national lecturer, he is coauthor of the casebook Tax Crimes: Cases & Materials and lead author of the chapter “Defending the Trust Fund Recovery Penalty—Section 6672” in the ABA’s Effectively Representing Your Client Before the IRS, and he speaks regularly at the NYU Institute on Federal Taxation, the ABA National Institute on Criminal Tax Fraud, and the International Symposium on Economic Crime in Cambridge, England, among many others.

• Experience

Larry’s practice encompasses business litigation, white-collar criminal defense, and federal, state, and local tax controversies, and over more than 45 years he has resolved thousands of civil and criminal litigation matters, many establishing precedent. Among his significant cases, in Johnson v. Sawyer he battled the IRS for 15 years to obtain damages for the wrongful disclosure of his client’s confidential tax information, with the Government eventually paying the nation’s largest settlement for wrongfully disclosing tax return information. He served as lead counsel in one of the largest project cases in the history of the United States Tax Court—involving over 2,000 petitioners—where his firm represented more than 700 taxpayers and negotiated both individual and generic settlements, and he represented the first taxpayer to be awarded attorneys’ fees by the U.S. Court of Appeals for the Fifth Circuit. His work spans IRS audits and appeals, criminal tax investigations and grand jury matters, employment tax and trust fund recovery penalty cases under Section 6672, eggshell audits, offshore voluntary disclosures and FBAR matters, reasonable cause penalty defenses, and tax malpractice defense.

Wendy Abkin, Esq., Partner | Abkin Law PLC

Wendy Abkin is a tax attorney with Abkin Law PLC in Berkeley, California, representing clients facing both routine and highly complex tax disputes with the IRS, California tax agencies, county Assessors and Assessment Appeals Boards, and city tax agencies. Her clients include individuals, trusts and estates, business entities (partnerships, LLCs, and corporations), and non-profits. With more than 35 years of experience as a tax lawyer, Wendy specializes in tax audits, administrative appeals, and litigating tax disputes, and she has worked both in private practice—with small, mid-size, and large law firms—and in government service. She regularly advises clients on California residency disputes and has assisted numerous trusts in understanding and managing their exposure to California income tax.

• Education & Credentials

Wendy earned her B.A., Magna Cum Laude, and her M.A., both from the University of California, Santa Barbara, and her J.D. and LL.M. in Taxation, both from the University of the Pacific, McGeorge School of Law. She was admitted to the State Bar of California in 1985.

• Recognition & Leadership

Wendy is a Fellow of the American College of Tax Counsel and a recipient of the V. Judson Klein Award from the State Bar of California Taxation Section (2007). She was part of Law360’s Practice Group of the Year for Tax (2017), recognized in The Best Lawyers in America (2010–2011), and named to Northern California Super Lawyers (2006–2022). Within the California Lawyers Association Taxation Section (previously the State Bar of California, Taxation Section), she is a member and past Chair of the Executive Committee. She has also served as Secretary/Treasurer and President of the San Francisco Tax Club and as Secretary, Vice-President, and President of the San Francisco Tax Litigation Club.

• Professional Involvement

Wendy is an active member of several professional organizations, including the California Lawyers Association Taxation Section, the American Bar Association Tax Section, the San Francisco Tax Club, and the San Francisco Tax Litigation Club. She speaks frequently on topics of tax controversy and tax procedure before legal and accounting professionals, including the California Lawyers Association Taxation Section, the American Bar Association Tax Section, the Practicing Law Institute, and the California Society of CPAs (various chapters). She regularly represents pro bono clients and previously served as an adjunct professor in both the School of Law and the Master’s in Taxation Program at Golden Gate University in San Francisco.

• Experience

Wendy has more than 35 years of experience as a tax lawyer specializing in tax audits, administrative appeals, and tax litigation. She began her career as a law clerk to the Hon. Charles E. Clapp II of the United States Tax Court and has substantial trial experience as a former IRS trial attorney, having worked with the IRS Office of Chief Counsel in San Francisco where she litigated cases for the IRS. For six years prior to joining Abkin Law, she was a partner in the tax practice of a global law firm. She has experience with a wide assortment of issues, including tax accounting, employment (payroll) taxes, tax shelters, bad debts, valuation, conservation easements, micro-captive insurance, foreign accounts and other offshore assets, civil and criminal tax issues and penalties, and collection of tax debts. She represents individuals, trusts and estates, partnerships, LLCs, corporations, and non-profits in disputes before the IRS, California tax agencies, county Assessors and Assessment Appeals Boards, and city tax agencies.

Ian M. Comisky, Esq., Partner | Fox Rothschild

Ian Comisky is a Partner at Fox Rothschild LLP, based in the firm’s Philadelphia office, with more than 35 years of experience representing corporations and individuals in civil and criminal tax litigation, white collar criminal defense, and complex corporate and commercial disputes. His experience includes tax controversy work such as IRS administrative and grand jury investigations, Tax Court, Claims Court, and District Court trials and appeals, jeopardy and termination assessments, and responsible officer penalty and collection matters; corporate compliance matters involving the Bank Secrecy Act, USA PATRIOT Act, and FATCA for financial institutions including banks, broker-dealers, and mutual funds; commercial litigation focused on accounting and legal malpractice as well as securities and class action matters; and corporate internal investigations, including claims under the Foreign Corrupt Practices Act. Ian frequently advises individuals on their U.S. tax and foreign asset reporting (FBAR and FATCA) obligations and has represented hundreds of individuals with undisclosed foreign bank accounts through the IRS voluntary disclosure programs, and he also counsels individuals and corporations in civil audits and criminal investigations arising out of tax sheltered investments.

• Education & Credentials

Ian earned his LL.M. from the University of Miami School of Law, his J.D. from the University of Pennsylvania Law School, and his B.S., magna cum laude, from the University of Pennsylvania. He is admitted to practice in Pennsylvania, Florida, and the District of Columbia, and before the U.S. Supreme Court, the U.S. Courts of Appeals for the Third, Eleventh, and Federal Circuits, the U.S. Court of Federal Claims, the U.S. District Courts for the Eastern and Middle Districts of Pennsylvania and the Southern and Middle Districts of Florida, and the U.S. Tax Court.

• Recognition & Leadership

Ian was elected in 1995 to the American College of Tax Counsel. He is recognized in the Chambers USA Guide for Litigation: White Collar Crime & Government Investigations in Pennsylvania (2022–2025), and is the recipient of the Pennsylvania Bar Association Criminal Justice Section’s Beacon of Liberty Award (2026). He has been selected to The Best Lawyers in America for Criminal Defense: White Collar Law in Philadelphia (2006–2026), to Super Lawyers for Tax in Pennsylvania (2017–2026), and to Benchmark Litigation’s list of “Local Litigation Stars” in Pennsylvania (2018–2026).

• Professional Involvement

Ian serves as special projects chair of the American Bar Association Tax Section and is a member of the Board of Governors of the Florida Bar, where he serves as chair of the Investment Committee. He is the co-author of the two-volume treatise Tax Fraud and Evasion, has appeared on CNBC’s Money Talk and CNN, and is called upon frequently to comment on tax issues; he also authors the firm’s Tax Controversy Sentinel blog. He is an adjunct professor at the University of Pennsylvania Law School. His memberships include the American Bar Association, the American College of Tax Counsel, the American Law Institute, the Association of Trial Lawyers of America, the Brandeis Society, the Federal Bar Association, the Florida Bar Association, the National Association of Criminal Defense Attorneys, the Pennsylvania Bar Association, the Philadelphia Bar Association, and the Public Liability Underwriters Society. He also serves on the boards of directors of the Citizens Crime Commission of the Delaware Valley, Historic Philadelphia, Inc., the Madlyn and Leonard Abramson Center for Jewish Life, and the Mann Center for the Performing Arts (as secretary).

• Experience

Ian has more than 35 years of experience representing corporations and individuals in civil and criminal tax litigation, white collar criminal defense, and complex corporate and commercial disputes. Prior to joining Fox Rothschild, he was co-chair of the white collar practice at Blank Rome for more than three decades, and before that served as an assistant district attorney in Philadelphia County, a special assistant U.S. attorney, and an assistant U.S. attorney in the Southern District of Florida. His work encompasses IRS administrative and grand jury investigations, trials and appeals in the Tax Court, Claims Court, and District Court, jeopardy and termination assessments, responsible officer penalty and collection matters, Bank Secrecy Act / USA PATRIOT Act / FATCA compliance for financial institutions, accounting and legal malpractice and securities litigation, and corporate internal investigations including FCPA claims. He has represented hundreds of individuals with undisclosed foreign bank accounts through the IRS voluntary disclosure programs and regularly counsels clients in civil audits and criminal investigations arising out of tax-sheltered investments.

Fran Obeid, Esq., Founder | MFO LAW, PC

Fran Obeid is the founder of MFO LAW, P.C. in New York City. She represents individual and corporate clients in civil and criminal matters involving the Internal Revenue Service, state and city tax agencies, the United States Attorney’s Office, the District Attorney’s Office, the New York State Attorney General, and 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, and she defends clients in federal and state audits, including residency and sales tax audits, while advising on how to prevent such audits. She regularly interacts with revenue officers and agents, IRS Appeals officers, IRS Counsel, criminal investigators, Assistant United States Attorneys, and Assistant Attorneys General, taking the right approach to best meet the client’s needs—whether defending a civil examination, criminal investigation or indictment, or subpoena demand.

• Education & Credentials

Ms. Obeid earned her LL.M. in Taxation from New York University School of Law, her J.D. from the Cardozo School of Law, and her Bachelor of Arts from the University of Michigan. She served as a Judicial Law Clerk to United States Magistrate Judge Henry Pitman (S.D.N.Y.). She is admitted to practice before the United States Supreme Court, the United States Court of Appeals for the Second Circuit, the United States Tax Court, the United States Court of Federal Claims, the New York State Courts, and the U.S. District Courts for the Southern and Eastern Districts of New York.

• Recognition & Leadership

Ms. Obeid is a member of the American College of Tax Counsel. She has been recognized as a Super Lawyer (2019–2025) and named to the inaugural Lawdragon 500 Leading Global Tax Lawyers (2025).

• Professional Involvement

Ms. Obeid is a member of the American College of Tax Counsel and served as Chair of the Personal Income Tax Committee of the New York City Bar (2015–2018). Within the American Bar Association, Tax Section, she serves as Co-Chair of the Civil and Criminal Tax Penalties Subcommittee of Legislative & Administrative Developments, and she is a Master of the Federal Bar Council Inn of Court. She is a frequent author and panelist on tax controversy topics, with recent engagements including “Avoiding and Abating Civil Tax Penalties” at the 17th Annual NYU Tax Controversy Conference (2025) and “Navigating the Current Tax Controversy Landscape” at the New York City Bar’s Tax Law Conference (2025). Her authored works include “Effectively Managing IRS Audits of High Net Worth Taxpayers” (Journal of Tax Practice & Procedure, Winter 2024), “Collecting More with Less” (Journal of Tax Practice & Procedure, 2018), and “Passport Revocation Begins For Seriously Delinquent Tax Debt” (New York Law Journal, 2018), and she has been quoted in The Wall Street Journal on settling with the IRS and on expatriation trends.

• Experience

Ms. Obeid represents individual and corporate clients across the full range of civil and criminal tax matters before the IRS, state and city tax agencies, the U.S. Attorney’s Office, the District Attorney’s Office, and the New York State Attorney General. She has represented numerous clients worldwide with undisclosed offshore accounts, advising on disclosure and compliance alternatives; defends clients in federal and state audits, including residency and sales tax audits; and represents non-filers and alleged responsible persons, having successfully obtained significant abatements of penalties. She has also represented individual witnesses and accounting firms before the U.S. Attorney’s Office, the Criminal Investigation unit of the IRS, and the New York State Attorney General. Her practice involves regular interaction with revenue officers and agents, IRS Appeals officers, IRS Counsel, criminal investigators, Assistant United States Attorneys, and Assistant Attorneys General across civil examinations, criminal investigations and indictments, and subpoena demands.

Sarah Green, Esq., Senior Managing Associate | Dentons Sirote

Sarah Green is a senior managing associate at Dentons Sirote in Birmingham, Alabama, where she is a member of the Tax practice. With a strong focus on tax controversy and litigation, she represents clients during all phases of federal income tax disputes, including IRS audits, administrative appeals, and court proceedings in the U.S. Tax Court, federal district court, and the U.S. Courts of Appeals. With experience navigating a diverse array of complex tax issues, Sarah focuses on federal and state civil tax controversies, including representing clients in sensitive audits, administrative appeals, and litigation. She also provides tax advice and represents individuals and entities in criminal tax investigations and prosecutions.

• Education & Credentials

She is based in Birmingham, Alabama, and practices in federal and Alabama state tax controversy matters and before the U.S. Tax Court, federal district courts, and the U.S. Courts of Appeals.

• Recognition & Leadership

Sarah was selected by the American Bar Association’s Section of Taxation as a member of the prestigious 2025–2026 class of John S. Nolan Fellows, an honor recognizing young tax attorneys for leadership and active contributions to the Section. She has been recognized by Best Lawyers for Litigation and Controversy–Tax and Tax Law, and named to Super Lawyers Rising Stars (2023–2025).

• Professional Involvement

Sarah serves as Vice Chair of the American Bar Association’s Section of Taxation, Standards of Tax Practice Committee, where her primary responsibility is arranging panels addressing critical topics in tax ethics and practice. She is an active speaker on the tax controversy circuit, including at the Hawaii Tax Institute and ABA Tax Section conferences.

• Experience

Sarah represents clients during all phases of federal income tax disputes, including IRS audits, administrative appeals, and court proceedings in the U.S. Tax Court, federal district court, and the U.S. Courts of Appeals. Her practice focuses on federal and state civil tax controversies, including representing clients in sensitive audits, administrative appeals, and litigation, and she also provides tax advice and represents individuals and entities in criminal tax investigations and prosecutions.

DAY 1, THURSDAY, JUNE 25, 2026

WELCOME – OPENING REMARKS | 8:00am – 8:05am

Kathleen Costello, CMP, Assistant Director, NYU School of Professional Studies, New York, NY

SESSION 1 – TAX COMPLIANCE AND ENFORCEMENT UPDATE: PART I | 8:05am – 8:30am

Amid an unprecedented federal workforce reduction, continuing IRS funding cuts, and dissolution of the DOJ Tax Division, today’s panels provide a comprehensive update on developments and priorities across the Treasury Department, DOJ Tax Division, and IRS relating to enforcement and compliance.

Caroline D. Ciraolo, Esq., Partner, Kostelanetz, Washington, DC

Pamela Grewal, Esq., Managing Director, Andersen Tax, San Francisco, CA

SESSION 2 – A VIEW FROM THE TOP – A CONVERSATION WITH IRS CEO FRANK BISIGNANO | 8:30am – 9:05am

IRS CEO Frank Bisignano shares his perspective on the agency’s strategic direction, operational priorities, and modernization efforts, addressing resource constraints, technology transformation, workforce initiatives, and the agency’s approach to enforcement and taxpayer service.

Moderator: Michael J. Desmond, Esq., Member and Tax Department Chair, Miller & Chevalier, Chartered, Washington, DC

Hon. Frank J. Bisignano, Chief Executive Officer, Internal Revenue Service, Washington, DC

SESION 3 – UPDATES FROM THE IRS COMPLIANCE OPERATIONS | 9:05am – 10:00am

As the IRS seeks to maximize human capital, tools, technology, and process efficiencies for sound tax administration encompassing both service and compliance, a panel of IRS compliance executives provides insight into IRS operations, resources, and priorities.

Moderator: Sharon Katz-Pearlman, Esq., Shareholder, Greenberg Traurig, New York, NY

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

Mabeline Baldwin, CPA, Acting Commissioner, Large Business and International Division, Internal Revenue Service, Washington, DC

Edward R. Killen, Esq., Commissioner, Tax Exempt and Government Entities, Internal Revenue Service, Washington, DC

Erick Martinez, Acting Director, Whistleblower Office, Internal Revenue Service, Washington, DC

Break | 10:00am – 10:10am

SESSION 4 – UPDATE FROM THE US TAX COURT AND THE IRS OFFICE OF CHIEF COUNSEL | 10:10am – 10:55am

This panel provides insight into the Tax Court’s operations, pending cases, and challenges in the current resource-constrained environment, and discusses the IRS Office of Chief Counsel’s leadership, staffing, workload, priorities, and field counsel’s role advising Exam and Appeals.

Moderator: Jennifer Breen, Esq., Partner, Morgan Lewis & Bockius, Washington, DC

Moderator: Diana L. Erbsen, Esq., Partner, DLA Piper, New York, NY

The Hon. Patrick J. Urda, Chief Judge, United States Tax Court, Washington, DC

Kenneth J. Kies, Esq., Acting Chief Counsel, Internal Revenue Service; Assistant Secretary, Tax Policy, US Department of the Treasury, Washington, DC

Break | 10:55am – 11:05am

SESSION 5 – ERC – FROM AMENDED RETURNS TO THE COURTROOM | 11:05am – 12:00pm

This panel explores the current landscape of Employee Retention Credit claims, including recent trends in audits, administrative appeals, and pending litigation, managing the risk of parallel proceedings, and best practices and strategies for substantiating and defending claims.

Moderator: Christopher M. Ferguson, Esq., Partner, Kostelanetz, New York, NY

Megan E. Marlin, Esq., Principal, PwC, Washington, DC

Daniel Graham Strickland, Esq., Partner, Holland & Knight, Washington, DC

Leila D. Carney, Esq., Member, Caplin & Drysdale, Chartered, Washington, DC

Eric Hylton, National Director, alliant, Washington, DC

Lunch | 12:00pm – 1:00pm

BREAK OUT SESSIONS | 1:00pm – 1:50pm

TRACK II

SESSION 6 – DEFINING AND DEFENDING ECONOMIC SUBSTANCE

The Codified Economic Substance Doctrine plays a critical role in high-stakes corporate and individual controversies, where the IRS challenges transactions lacking non-tax economic impact or business purpose; this panel covers enforcement trends, court decisions, the two-prong test, and prevention best practices.

Moderator: David W. Foster, Esq., Partner, Kirkland & Ellis, Washington, DC

Nikki S. Bossert, Esq., Senior Technician Reviewer, Office of the Associate Chief Counsel (Procedure & Administration), Internal Revenue Service, Washington, DC

Julie Ciamporcero Avetta, Esq., Senior Attorney Advisor, Litigation, Tax Law Center at NYU School of Law, New York, NY

S. Starling Marshall, Esq., Partner, Crowell & Moring, New York, NY

Break | 1:50pm – 2:10pm

BREAK OUT SESSIONS | 2:10pm – 3:00pm

TRACK II

SESSION 7 –  A GUIDE TO UNDERSTANDING BBA AUDITS AND APPEALS

With the centralized partnership audit regime now the reality, this panel covers the audit framework, expected notices, recent trends, required actions, methods to challenge proposed adjustments, the impact on individual partners, best practices, and cautionary tales.

Moderator: Ellen S. Brody, Esq., Partner, Roberts & Holland, New York, NY

Jonathan Kalinski, Esq., Principal, Hochman Salkin Toscher Perez, PC, Beverly Hills, CA

Matthew Cooper, Esq., Principal, Deloitte Tax, Washington, DC

Cory Ellenson, Esq., Managing Director, Andersen Tax, Washington, DC

Break | 3:00pm – 3:20pm

BREAK OUT SESSIONS | 3:20pm – 4:10pm

TRACK II

SESSION 8 – IS THE TIDE FINALLY TURNING? UPDATE ON FBAR LITIGATION

With the IRS prioritizing offshore compliance, this panel updates current trends in Bank Secrecy Act examinations, related appeals, and federal litigation, analyzing landmark decisions and constitutional challenges that may seismically impact the entire FBAR penalty regime.

Moderator: Zhanna A. Ziering, Esq.,  Managing Member, Ziering & Esman, New York, NY

Jason B. Freeman, Esq., Managing Member, Freeman Law PLLC, Dallas, TX

Jeffrey A. Neiman, Esq., Partner, Neiman Mays Floch & Almeida PLLC, Fort Lauderdale, FL

Chad M. Vanderhoef, Esq., Partner, Holland & Knight, Tampa, FL

Break | 4:10pm – 4:30pm

BREAK OUT SESSIONS | 4:30pm – 5:30pm

TRACK II

SESSION 9 – OBTAINING, DEFENDING, AND RETAINING TAX CREDITS

This panel discusses the substantial uptick in audits regarding energy tax credits and research and development credits, the hot issues the IRS is considering, and practical tips for dealing with such controversies.

Moderator: Amish Shah, Esq., Partner, Holland & Knight, Washington, DC

Carina C. Federico, Esq., Partner, Crowell & Moring, Washington, DC

Joshua D. Smeltzer, Esq., Partner, Gray Reed, Dallas, TX

Kathleen King, CPA, Managing Director, Alvarez & Marsal Tax, Washington, DC

Andrew Weiner, Esq., Counsel, Kostelanetz, Washington, DC

DAY2, FRIDAY, JUNE 26, 2025

SESSION 1 – TAX COMPLIANCE AND ENFORCEMENT UPDATE: PART II | 8:30am – 9:00am

WELCOME ABOARD! A CONVERSATION WITH THE DOJ CIVIL DIVISION TAX LITIGATION BRANCH

With civil tax litigation now under the new DOJ Civil Division Tax Litigation Branch, inaugural head Joshua Wu discusses the office’s creation, mission, role in refund litigation, early priorities, and what the structural shift means for practitioners.

Moderator: Caroline D. Ciraolo, Esq., Partner, Kostelanetz, Washington, DC

Joshua Wu, Esq., Deputy Assistant Attorney General for the Tax Litigation Branch, US Department of Justice, Civil Division, Washington, DC

Break | 9:00am – 9:10am

SESSION 2 – FOLLOWING THE MONEY: A CONVERSATION WITH JAROD KOOPMAN, CHIEF, IRS CRIMINAL INVESTIGATION | 9:10am – 9:40am

IRS-CI Chief Koopman discusses the agency’s staffing, resources, global footprint, and enforcement priorities, focusing on how CI identifies and develops cases involving complex financial transactions, digital assets, and cross-border activity, plus investigative trends and interagency coordination.

Moderator: Don Fort, CPA, Senior Investigator, Kostelanetz, Washington, DC

Moderator: Guy Ficco, CFE, Senior Investigator, Kostelanetz, Washington, DC

Jarod Koopman, Chief, Criminal Investigation Division; Chief Tax Compliance Officer, Internal Revenue Service, Washington, DC

Break | 9:40am – 9:50am

SESSION 3 – NEW DOJ NATIONAL FRAUD ENFORCEMENT DIVISION | 9 :50am – 10 :20am

As DOJ intensifies its crackdown on financial fraud, this panel offers a rare chance to hear from Department leadership about the new National Fraud Enforcement Division’s mission, leadership, staffing, resources, enforcement priorities, and achievements combatting criminal tax violations.

Moderator: Karen E. Kelly, Esq., Partner, Kostelanetz, Washington, DC

Stephen Weiss, Esq., Associate Deputy Attorney General, Office of the Deputy Attorney General,, US Department of Justice, Washington, DC

Break | 10:20am – 10:35am

SESSION 4 – A LOOK INSIDE TREASURY: A CONVERSATION WITH SHELLEY LEONARD, DEPUTY TAX LEGISLATIVE COUNSEL | 10:35am – 11:05am

Deputy Tax Legislative Counsel Shelley Leonard provides a look inside Treasury’s role in offering legal and policy advice on tax legislation, regulations, and guidance, addressing current legislative and regulatory priorities, the rulemaking process, and real-world impacts of recent changes.

Moderator: Scott Levine, Esq., Partner, Baker McKenzie, Washington, DC

Shelley Leonard, Esq., Deputy Tax Legislative Counsel, Office of Tax Policy, US Department of the Treasury, Washington, DC

Break | 11:05am – 11:15am

SESSION 5 – LEADING THE CHARGE: A CONVERSATION WITH ERIN COLLINS, NATIONAL TAXPAYER ADVOCATE | 11:15am – 11:45am

National Taxpayer Advocate Erin Collins provides an inside look at the current state of tax administration, the impact of the 2026 filing season, NTA’s June Objective Report to Congress, the Taxpayer Assistance and Service Act, and protecting taxpayer rights.

Moderator: Pamela Grewal, Esq., Managing Director, Andersen Tax, San Francisco, CA

Erin M. Collins, Esq., National Taxpayer Advocate, Internal Revenue Service, Washington, DC

Lunch | 11:45am – 12:10pm

SESSION 6 – GUIDING THE EXEMPT ORGANIZATION IN AN ERA OF ENHANCED ENFORCEMENT | 12:10pm – 1:10pm

With exempt organizations facing unprecedented scrutiny under Executive Orders, this panel examines current audit trends, compliance challenges, and key risk areas including governance, unrelated business income, and operational compliance, plus strategies for examinations and raising constitutional challenges.

Moderator: Meghan R. Biss, Esq., Partner, Loeb & Loeb, Washington, DC

Susanne Sachsman Grooms, Esq., Partner, Cooley, Washington, DC

Casey A. Lothamer, Esq., Senior Counsel, Loeb & Loeb, Washington, DC

Michelle McCarthy, Esq., Senior Manager, RSM US, Hartford, CT

Break | 1:10pm – 1:30pm

BREAK OUT SESSIONS | 1:30pm – 2:20pm

TRACK II

SESSION 7 – OUR FRIENDS TO THE NORTH: RULES OF THE ROAD FOR US CANADA CROSS BORDER TAX CONTROVERSIES

This panel explores cross-border controversy issues including coordinated enforcement, exchange of information, limitation periods, and dispute resolution under the Canada-US treaty, following an imagined case study through procedural steps and managing cross-border audits, MAP/ACAP, and multijurisdictional litigation.

Moderator: Christopher Slade, Esq., Partner, Aird & Berlis, Toronto, Canada

Amanda P. Swartz, Esq., Of Counsel, Meadows, Collier, Reed, Cousins, Crouch & Ungerman, Dallas, TX

J. Clark Armitage, Esq., Member, Caplin & Drysdale, Chartered, Washington, DC

Amie Colwell Breslow, Esq., Of Counsel, Jones Day, Washington, DC

Break | 2:20pm – 2:35pm

BREAK OUT SESSIONS | 2:35pm – 3:35pm

TRACK II

SESSION 8 – TAX EVASION OR PROFESSIONAL OVERSIGHT? ANALYZING THE PROSECUTION OF THOMAS GOLDSTEIN *ETHICS

As state and local authorities increase enforcement following the federal workforce reduction, this panel examines audit trends including nexus determinations, apportionment disputes, and data analytics, plus strategies for multistate controversies, coordinating with federal proceedings, and the ethical challenges of managing noncompliance.

Moderator: Tino M. Lisella, Esq., Shareholder, Carlton Fields, West Palm Beach, FL

Rod J. Rosenstein, Esq., Partner, Baker & McKenzie, Washington, DC

Carlos F. Ortiz, Esq., Partner, BakerHostetler, New York, NY

Sara G. Neill, Esq., Shareholder, Neill Schwerin Boxerman, PC, St. Louis, MO

Break | 3:35pm – 3:50pm

BREAK OUT SESSIONS | 3:50pm – 4:50pm

TRACK II

SESSION 9 – COMING IN TO COMPLIANCE – WHAT ARE THE OPTIONS?

For taxpayers who have fallen out of compliance, this panel examines available pathways including voluntary disclosure programs, streamlined filing procedures, qualified amended returns, and other corrective measures, plus the benefits, risks, strategic decisions, and recent enforcement trends.

Moderator: Larry A. Campagna, Esq., Shareholder, Chamberlain, Hrdlicka, White, Williams & Aughtry, PC, Houston, TX

Wendy Abkin, Esq., Partner, Abkin Law PLC, Berkeley, CA

Ian M. Comisky, Esq., Partner, Fox Rothschild, Philadelphia, PA

Fran Obeid, Esq., Founder, MFO LAW, PC, New York, NY

Sarah Green, Esq., Senior Managing Associate, Dentons Sirote, Birmingham, AL