16th Annual Tax Controversy Forum – Track I (presented by NYU School of Professional Studies) [Day 2]

Sharon Katz-Pearlman, Esq. | Greenberg Traurig

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

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

Lia Colbert | Internal Revenue Service

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

Heather Maloy, Esq. | Internal Revenue Service

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

Holly O. Paz, Esq. | Internal Revenue Service

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

Don Fort, CPA. | Kostelanetz LLP

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

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

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

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

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

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

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

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

Guy Ficco | Internal Revenue Service

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

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

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

Jason B. Freeman, Esq. | Freeman Law PLLC

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Jacqueline Laínez Flanagan, Esq. | Center for Taxpayer Rights

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

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

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

Carlos F. Ortiz, Esq. | BakerHostetler

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

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

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

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

Anna C. Tavis | Brooklyn Legal Services

Staff Attorney, Brooklyn Legal Services, Brooklyn, NY.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Sharyn M. Fisk, Esq. | Internal Revenue Service

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

Eric Hylton | Alliantgroup

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

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

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

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

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

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

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

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

John W. Hinman | Whistleblower Office, Internal Revenue Service

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

Beverly Winstead, Esq. | Law Office of Beverly Winstead

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

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

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

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

Mary Beth Murphy | Internal Revenue Service

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

Todd Welty

Erin M. Collins, Esq. | Internal Revenue Service

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

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

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

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

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

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

Jennifer Breen, Esq. | Morgan Lewis & Bockius

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

Diana L. Erbsen, Esq. | DLA Piper

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

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

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

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

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

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

Judge, United States Tax Court, Washington, DC

John Colvin, Esq. | Colvin + Hallet

John draws from his almost three decades of practice and experience in tax law to develop legal theories and strategies in defense of his clients. John keeps a close eye on developments in the tax law, which enables him to provide his clients an unparalleled awareness of current developments and their implications.

John is a very active and respected member of the American Bar Association Tax Section, having served as Chair of the Committee covering tax controversy matters, and currently overseeing Tax Section comments on government regulatory efforts in the procedural areas as part of the Committee on Government Submissions. He is often sought out to speak at a national level on various tax law issues, and has been intimately involved in drafting comments to proposed regulations on a variety of topics on behalf of the ABA Tax Section. He also teaches Tax Crimes: Investigations, Prosecutions, and Penalties at the University of Washington School of Law.

John is a wine and food connoisseur and is always on the lookout for Seattle’s next great restaurant. He enjoys swimming and, in addition to tax news, is an avid reader of non-tax materials.

Meghan R. Biss | Loeb & Loeb LLP

Meghan Biss represents a diverse array of nonprofit and tax-exempt organizations, including private foundations, national and foreign charities, social welfare organizations, colleges and universities, government agencies, lobbying and political organizations, and trade associations. Meghan utilizes her more than 10 years of experience at the Internal Revenue Service (IRS) to guide clients through IRS processes and help them achieve their programmatic and philanthropic objectives. She advises organizations throughout the tax planning process and guides them through IRS and state attorney general investigations, including audits conducted by the IRS’ Exempt Organizations division.

During her time at the IRS, Meghan served as senior technical advisor to the director of exempt organizations. In this role, she advised on all matters related to nonprofits and tax-exempt organizations, including overhauling the application process and enhancing the data-driven approach to examinations. Meghan also collaborated with the IRS Chief Counsel and the Treasury Department in 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 Department of Justice on exempt organization litigation.

Prior to her position as senior technical advisor, Meghan accumulated a wide range of experience within the public sector, addressing issues such as disaster relief, unrelated business income tax (UBIT), excess benefit transactions, charter and private schools, and environmental concerns. As a presidential management fellow, Meghan also served as a special attorney in the Civil Appellate Section of the Tax Division at the U.S. Department of Justice, where she handled a variety of appellate tax litigation issues.

Meghan is a frequent speaker at national industry institutes, seminars and conferences on legal issues concerning nonprofits and tax-exempt organizations.

Casey A. Lothamer, Esq. | Internal Revenue Service

Area Counsel, Mid-Atlantic Region, Tax Exempt Government Entities, Internal Revenue Service, Washington, DC.

Josh O. Ungerman, Esq., CPA | Meadows, Collier, Reed, Cousins, Crouch & Ungerman

Mr. Ungerman’s experience as a former IRS Senior Trial Attorney and Department of Justice (DOJ) Special Assistant U.S. Attorney are invaluable in helping clients with IRS civil tax and criminal tax controversy matters at all levels along with tax and estate planning. The tax and estate matters in which Josh is involved are typically very complex from both a factual and legal perspective. These matters often require legal and accounting skills. Josh is also a Certified Public Accountant.

Mr. Ungerman is involved in defending Taxpayers & issues against IRS inquiries and actions. The IRS defense practice covers Civil and Criminal Exams, Investigations and Trials. Many of Josh’s Tax Controversy matters include an offshore component.

Mr. Ungerman is often called upon to remediate non-compliant offshore structures and advise on offshore compliance requirements.

Mr. Ungerman is selected to many “Best of” attorney lists by his peers including: Best Lawyers, D Magazine and Texas Monthly. Mr. Ungerman has been recognized by the Best Lawyers® in America as the 2023 Litigation and Controversy-Tax Law “Lawyer of the Year” in the Dallas/Fort Worth area. He was also selected to the Texas Super Lawyers Top 100 Lawyers list.

Prior to joining the firm in 1994, he was a civil prosecutor for the Internal Revenue Service, Dallas District Counsel office. He was also a Special Assistant United States Attorney for the Department of Justice in Dallas during his time as a civil prosecutor. Prior to becoming an IRS Attorney of a Special Assistant U.S. Attorney, he served as a law clerk to the Honorable Carolyn M. Parr at the United States Tax Court in Washington, D.C.

Josh is a frequent speaker on tax topics including domestic and offshore IRS exams, IRS estate tax strategies, tax shelter defense, recent tax legislation, IRS criminal tax investigation techniques, state tax controversy issues and IRS offshore compliance issues.

Mr. Ungerman was admitted to practice in Texas in 1990.

Walter Pagano, CPA, CFE, CFF | EisnerAmper

Walter Pagano is a Tax Partner with more than 35 years of diversified and relevant litigation consulting and forensic accounting experience. He has testified in federal and state courts, as well as at arbitration hearings, and has served as a federal, state, and bankruptcy court appointed forensic accountant and special fiscal agent. Walter’s experience, knowledge, and expertise enable practicing attorneys and corporate counsel to rely on his objective and independent critical thinking and judgment as a source to ascertain the financial facts in a wide variety of civil and criminal cases that have included white collar crime, internal investigations, adequacy of internal controls, commercial disputes, civil and criminal tax controversy, internal and external fraud schemes, financial statement fraud, shareholder and matrimonial disputes, guardianship litigation, accounting malpractice and third-party asset misappropriation. Walter has served as an expert witness in diverse cases such as IRS practice and procedure, breach of accounting and tax representations and warranties, damage calculations, criminal tax prosecutions, and guardianship accounting.

Prior to joining the firm, Walter served as Partner-in-Charge of Litigation Consulting and Forensic Accounting at another public accounting firm. His background also includes serving 10 years as a revenue agent with the United States Treasury Department, Internal Revenue Service (IRS). In this position, Walter conducted forensic and tax audits of businesses and individuals, and also trained revenue agents and criminal investigation special agents in the applicable provisions of income tax law. In addition, he was an appeals officer, co-authored the IRS’ Commodity Tax Shelter Training Manual, examined abusive tax shelters, and assisted federal prosecutors as a forensic accountant in prosecuting various tax crimes.

Walter is a frequent guest speaker on topics such as forensic accounting, IRS investigations and white collar crime.

Kevin Hanff | Integritas³

Kevin spent 23 years as a Special Agent at IRS Criminal Investigation. The first 10 years were in St. Louis, before he was selected as a Resident Lead Instructor at the Federal Law Enforcement Training Center (FLETC) in Brunswick, Georgia. Kevin taught the Seized Computer and Evidence Recovery Specialist (SCERS) classes before being selected as a Supervisory Special Agent in Mobile, Alabama. A second tour-of-duty at the FLETC (as an International Instructor and Accreditation lead) was followed by his selection as Assistant Special Agent in Charge in the Seattle Field Office.

As CIO at Integritas³, Kevin provides computer hardware, software and information security support. His background as a computer investigative specialist and lead instructor at the Federal Law Enforcement Training Center gives Integritas³ the ability to analyze, respond, and support your digital investigative need for forensic accounting, tax, and compliance analysis.

Susan Markel, CPA | AlixPartners, LLP

Susan oversees matters involving corporate financial reporting, regulatory investigations, whistle-blower actions, Foreign Corrupt Practices Act (FCPA) enforcement, and internal controls. Formerly at the US Securities and Exchange Commission (SEC), she served as chief accountant of the enforcement division. Susan was named to Global Investigation Review’s 2021 “Women in Investigations” and listed as one of GIR’s “Top FCPA Practitioners”. She has received several awards including the SEC’s Distinguished Service Award in 2006 and The National Law Journal’s 2014 “Governance, Risk and Compliance Trailblazer and Pioneer”. She is a speaker nationally and internationally on public reporting and accounting related to financial fraud investigations and other enforcement actions involving the SEC and other government entities. She has a Bachelor of Science in accounting from the University of Akron, is a CPA and certified in financial forensics.

Manny Muriel, MBA, EA.

Guinevere M. Moore | Moore Tax Law Group, LLC.

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 offices in Chicago and New York.

Guinevere has over fifteen years of experience helping taxpayers resolve significant disputes with the IRS and state tax agencies. She routinely represents taxpayers in high-stakes criminal and civil tax disputes. At Moore Tax Law Group LLC, we take a holistic approach to representing clients. We believe the only way to accomplish the best possible outcomes for our clients is by truly getting to know our clients. Some clients want to win at all costs. Some clients want to resolve the issue as quickly as possible, and are willing to concede issues they would likely win in litigation in order to put the problem with the IRS behind them. Most fall somewhere in between. Guinevere gets to know her clients and ensures that she has a deep understanding of their needs and preferences before developing a strategy for the case.

She is a frequent speaker and author, routinely publishing articles and speaking at conferences around the world on tax controversy and tax litigation in Forbes, Bloomberg, and Tax Notes.

Guinevere lives in Chicago with her husband and their four children. She enjoys being active and all of her best ideas come to her while riding her bike to work, running, walking, or rowing.

Sara G. Neill, Esq. | Neill Schwerin Boxerman, P.C.

Jeffrey A. Neiman, Esq. | Marcus Neiman Rashbaum & Pineiro

Jeffrey Neiman is an experienced trial lawyer who regularly defends individuals and corporations in white collar criminal litigation, matters involving tax controversies, government regulatory enforcement matters, internal investigations, compliance counseling, and complex civil litigation. Jeff has tried more than a dozen white collar matters in federal court. Having worked at the forefront of the United States government’s offshore tax enforcement efforts, Jeff has vast experience assisting clients who find themselves with unreported or undeclared bank accounts outside of the United States. Jeff advises clients regarding the Internal Revenue Service’s Offshore Voluntary Disclosure Program as well as clients who face civil and criminal penalties for failing to file Foreign Bank Account Reports (“FBARs”).

Rod J. Rosenstein, Esq. | King & Spalding

Drawing upon three decades of experience as a federal prosecutor and senior government official, former Deputy Attorney General Rod Rosenstein helps clients resolve sensitive regulatory, enforcement and litigation challenges. His practice focuses on government investigations, crisis management, national security and cyber issues, tax controversies, compliance and monitoring.

Rod served in leadership positions in the U.S. Department of Justice during the administrations of Presidents George W. Bush, Barack Obama and Donald Trump, including as Deputy Attorney General and U.S. Attorney for Maryland. He personally represented the United States in 23 jury trials and argued 21 appeals in various appellate courts and the U.S. Supreme Court.

As the second-highest ranking Department of Justice official from 2017 to 2019, Rod was responsible for overseeing 115,000 employees nationwide in the litigating divisions, law enforcement agencies and U.S. Attorney’s Offices. He revised policies concerning corporate criminal prosecutions and parallel domestic and foreign investigations, Foreign Corrupt Practices Act matters, and health care fraud cases. He also reviewed significant proposed criminal and civil enforcement actions, False Claims Act settlements, and corporate monitor appointments. Rod led the Task Force on Market Integrity and Consumer Fraud and the Cyber-Digital Task Force, and he handled national security matters reviewed by the Committee on Foreign Investment in the United States (CFIUS).

Carina C. Federico, Esq. | Crowell & Moring

Clients trust Carina Federico to advise on wide-ranging, complex tax issues, including transfer pricing, investment tax credits, research and experimentation credits, and energy credits. Carina Federico 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.

Shirley Chin | WTW

Shirley Chin brings more than 25 years of legal experience to WTW, spanning the private, public, government and non-profit sectors. Most recently, she worked for more than 9 years as an energy tax attorney, serving as the Vice President of Tax at Sunrun, a residential solar, storage, and energy services company. She also worked at the IRS Office of Chief Counsel, Large Business and International Division, along with working as a tax law attorney at two major N.Y. law firms. Ms. Chin earned her joint law and public administration degrees from the University of California, Berkeley School of Law, and Harvard University. She also has her CPA license and is admitted to both the NY and CA state bars.

Ian M. Comisky, Esq. | Fox Rothschild

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.

Mark Nyman | Internal Revenue Service

Director, Corporate Issues/Credits, Internal Revenue Service, New York, NY.

Philip J. Wilson, CPA. | Marcum

Philip Wilson is office managing partner of Marcum’s Costa Mesa, California, office and is leader of the Firm’s national Tax Controversy group. Mr. Wilson has more than 30 years of CPA and business advisory experience, including experience as an IRS revenue agent.

Mr. Wilson focuses on helping individuals and companies resolve tax
controversies with the Internal Revenue Service, representing all types of businesses as well as high net worth individuals.

Prior to joining Marcum LLP, Mr. Wilson was a founding partner of WilsonMorgan LLP, based in Irvine. He oversaw all of the firm’s tax compliance, tax consulting, and tax controversy engagements. He has substantial experience in the real estate area, including tax structuring for commercial and residential developers, and has worked with clients in a wide variety of industries.

Christopher M. Ferguson, Esq. | Kostelanetz

Mr. Ferguson 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, anti-trust violations (bid rigging and price fixing), 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.

In his civil practice, Mr. Ferguson has represented both plaintiffs and defendants in a variety of complex commercial matters, including wage and hour class actions, 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.

Mr. Ferguson also conducts internal investigations for institutional clients whose officers and/or employees have been suspected or accused of wrongdoing.

Mr. Ferguson received his B.A., magna cum laude, from Boston College and his J.D. from New York University School of Law. 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.

Mr. Ferguson is recognized in Super Lawyers and is a member of the New York Council of Criminal Defense Lawyers. He is also the former Secretary of the Criminal Law Committee of the Bar Association of the City of New York and has published and spoken extensively in the areas of white collar criminal and civil and criminal tax controversies.

Megan Marlin | PwC

Megan is a partner in the Workforce Transformation group at PwC.

Her practice is focused on employment tax consulting for public and private companies and tax-exempt employers. She advises employers on worker classification, fringe benefits, global mobility, remote and hybrid work arrangements, legal entity simplification, payroll transformation, post-deal integration, and payroll tax compliance. Megan 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 with the Joint Committee on Taxation. She assisted congressional tax-writing committees and members of Congress with the development and analysis of legislative proposals.

Richard J. Sapinski, Esq. | Sills Cummis & Gross PC.

Richard J. Sapinski is Co-Chair of the Firm’s Tax Fraud and Controversy Practice Group. His practice involves white collar criminal defense on both federal and state levels and civil and criminal tax litigation, as well as international tax reporting and compliance issues. Prior to joining the Firm, Mr. Sapinski was employed by the Office of the District Counsel, Internal Revenue Service, Newark, New Jersey as a trial attorney from 1977 to 1984 and later with the Office of the Regional Counsel Internal Revenue Service, Philadelphia, Pennsylvania, as a Special Trial Attorney from 1985 to 1987. In the latter position, Mr. Sapinski was assigned responsibility for litigating in the United States Tax Court on behalf of the Commissioner of Internal Revenue in large and sensitive cases and for assisting IRS international examiners in developing international tax issues for litigation. He litigates matters in the United States District Court, U.S. Tax Court and the Superior Court and Tax Court of New Jersey and the Federal and State Appellate Courts. He also represents professionals before disciplinary and licensing boards and handles administrative matters involving the Examination, Collection and Criminal Investigation divisions of the Internal Revenue Service and their state counterparts.

James A. Ulicny, Esq | Internal Revenue Service

Attorney, Office of Chief Counsel (Criminal Tax), Internal Revenue Service, New York, NY.

Phillip Colasanto, Esq | Withersworldwide

His practice is focused on domestic and international tax controversy and compliance matters. He has represented clients before the U.S. Tax Court, U.S. district court, U.S. Court of Appeals, and various state courts. He has represented clients from audit through trial and at the appellate level.

His experience includes examinations, collection matters, Appeals hearings (including collection due process hearings), innocent spouse relief, whistleblower claims, advising clients on international and domestic filing requirements, advising clients on compliance options, and oral argument before the Tax Court and Court of Appeals.

Phillip received the New York County Lawyers’ Association Pro Bono Award in 2022. He was also recognized as a John S. Nolan Fellow by the American Bar Association in 2019-2020. He has spoken on various tax topics and at various forums, including the American Bar Association, New York County Lawyers’ Association, IRS Nationwide Virtual Tax Forum, CPA Academy, and NYU Tax Controversy Forum. He has also published several tax-related articles, which have been published by Tax Notes, Bloomberg BNA, Journal of Tax Practice and Procedure, EA Journal, and The Practical Lawyer. In addition to his publications and speaking engagements, he is heavily involved with the American Bar Association, where he is the Chair of the Tax Collections Bankruptcy and Workouts Committee.

Yvonne R. Cort, Esq. | Capell Barnett Matalon & Schoenfeld

Yvonne R. Cort is a Partner at Capell Barnett Matalon & Schoenfeld LLP, where she focuses her practice on resolving Federal and New York State tax controversies.

For over twenty years, Yvonne has assisted individuals and businesses with IRS and NYS tax matters including New York State and New York City residency audits, IRS and NYS audits and appeals, unfiled returns, income tax, sales tax, withholding tax, responsible person assessments, liens and levies, tax warrants, innocent spouse, voluntary disclosure, installment agreements and offers in compromise.

Yvonne has been selected to New York Metro SuperLawyers, a designation given to only 5% of the lawyers in the state. She has served as Chair of the IRS Downstate New York Practitioner Liaison Group and Chair of the Business Law, Tax and Accounting Committee of the Nassau County Bar Association. She is a member of the Executive Committee of the NYS Bar Association Tax Section, where she has contributed to policy papers. She is also a Co-Chair of the Attorneys and Accountants Joint Committee of the NYS Society of CPAs, Nassau Chapter. Yvonne has been honored as a Long Island Business News Top 50 Women in Business and is a recipient of the Long Island Power Women in Business award from Long Island Press.

Yvonne’s numerous articles on tax topics have been featured in accounting and legal publications such as the Journal of Multistate Taxation and Incentives, and the Tax Stringer, published by the New York State Society of CPAs. She is a regular speaker for many professional groups. Yvonne has been interviewed by various media outlets, and she has been quoted in leading publications including Bloomberg BNA, Crain’s New York Business, and Newsday.

Yvonne received her B. A. magna cum laude from the University of Rochester, and her J.D. from the University of Pennsylvania Carey Law School. Yvonne is admitted to the Bar in New York and Pennsylvania and admitted to practice before the United States Tax Court.

She is a Steering Committee Member for Women Owned Law.

Jay R. Nanavati, Esq. | Kostelanetz

Mr. Nanavati is a criminal tax defense attorney and a fellow of both the American College of Trial Lawyers and the American College of Tax Counsel. According to Chambers USA, which has ranked him nationally for the last seven years, Mr. Nanavati “is held in high regard for his strength in handling criminal tax matters . . . . He is an excellent trial attorney, he’s very sophisticated. His judgment is excellent.”

Mr. Nanavati represents individuals and entities facing investigations and prosecutions by the IRS, the FBI, state investigative agencies, U.S. Attorney’s offices, and the Department of Justice Tax Division. His clients rely on his ability to analyze cases from the government’s perspective and trust his sound judgment to guide them through their most difficult challenges.

Mr. Nanavati has defended clients against federal investigations and charges throughout the country. He regularly handles matters involving allegations of offshore tax evasion, employment tax violations, cryptocurrency reporting violations, use of shell companies, currency reporting violations, and underreporting of business income. He also has substantial experience representing clients accused of promoting or participating in so-called tax shelters, including captive insurance programs, conservation easements, and Puerto Rico’s Act 20/Act 22 program. In many instances, Mr. Nanavati represents tax professionals facing such accusations.

Mr. Nanavati spent more than a decade as both a federal and a state prosecutor. At the Department of Justice’s Tax Division, he supervised more than 30 federal tax prosecutors and oversaw criminal tax enforcement for a region covering 22 states. He investigated and prosecuted, among many other tax offenses, an e-commerce tax fraud scheme, a thoroughbred race horse tax fraud scheme, an abusive trust scheme, and numerous individuals and businesses engaged in tax evasion. In addition to the cases that he prosecuted, he was also responsible for reviewing and authorizing criminal tax grand jury investigations and prosecutions in the various U.S. Attorney’s Offices in his 22-state region. He is a veteran trial lawyer, having conducted dozens of jury trials and hundreds of bench trials.

Mr. Nanavati is a member of the ABA’s Section of Taxation, Civil and Criminal Tax Penalties Committee, as well as of the ABA’s Criminal Justice Section, White Collar Crime Committee, and a member of the Edward Bennett Williams Inn of Court.

From 2013 to 2016, Mr. Nanavati assisted the White House Office of Presidential Personnel in a pro bono capacity by vetting potential presidential appointees for possible tax-related problems.

Melissa L. Wiley, Esq. | Lowenstein Sandler

She is a highly skilled tax controversy and litigation attorney with 20 years of experience in a wide range of civil tax matters at the federal and state level. Throughout her career, both clients and colleagues have praised her for her calm, empathetic style and ability to translate complex concepts into easily understandable elements. An actuary by training, she is relentlessly detail-oriented and thorough, without losing the ability to see the bigger picture. She is also deeply committed to pro bono service, representing children and caretakers in the District of Columbia in custody and abuse/neglect matters.

Andrew Strelka | Latham & Watkins

Andrew Strelka is counsel in the Tax Practice, drawing on significant government experience to advise clients on tax-related disputes and litigation.

Mr. Strelka most recently served as Senior Tax Counsel in the Biden White House, providing advice on all manner of issues relating to federal taxation, as well as overseeing the vetting and Senate confirmation process. Previously, he served in the Department of Justice Tax Division (DOJ), where he litigated a variety of civil tax matters involving tax-exempt organizations, tax refund suits, matters concerning the Administrative Procedure Act, and transfer pricing disputes. While with the DOJ, Mr. Strelka was detailed to the Obama White House, where he served in a similar tax advisory role. In 2013, he received the DOJ Tax Division’s Outstanding Attorney Award, and in 2012 he received the FBA Younger Federal Lawyer Award.

Prior to his time at DOJ, Mr. Strelka was a Presidential Management Fellow, splitting his time between the Internal Revenue Service, where he issued rulings and guidance on tax-exempt organizations, and the D.C. US Attorney’s Office, representing the United States in complex civil litigation.

Mr. Strelka represents clients across industries, including global nonprofits, private equity, oil and gas, technology, and international financial institutions. He advises on a full range of tax controversy matters with particular focus on district court tax litigation, IRS appeals, summonses and enforcement, exempt organizations, Administrative Procedure Act issues, and federal excise tax issues.

Prior to joining Latham, Mr. Strelka served as counsel at a tax boutique law firm, representing taxpayers in all manner of tax litigation and tax controversy.

Mr. Strelka has held numerous bar association positions, including the 2013/2014 National Chair of the FBA Section on Taxation.

Benjamin Alarie, Esq. | Blue J

Robert J. Kovacev, Esq. | Miller & Chevalier

Robert J. Kovacev’s practice focuses on federal tax controversy and tax litigation. He combines extensive first-chair litigation skills with substantive tax knowledge to represent taxpayers in high-profile, high-stakes tax disputes against the Internal Revenue Service (IRS), both at the administrative level and in litigation. These disputes include international tax and transfer pricing issues, the research tax credit, the Section 199 domestic production activities deduction, alternative energy tax credits, and the economic substance doctrines. Mr. Kovacev has more than two decades of experience representing clients in Tax Court and in federal district and appellate courts. Recognized by Forbes for having one of the top tax-related Twitter accounts, Mr. Kovacev is a leader in the emerging field of taxation of robotics and artificial intelligence, and he frequently writes and speaks on the topic.

Prior to joining Miller & Chevalier, Mr. Kovacev was a partner at a global law firm. Before entering private practice, he was a senior litigation counsel in the Tax Division of the U.S. Department of Justice (DOJ), where he was lead trial counsel for the IRS in some of the largest and most complex civil tax cases in the nation. In that position, Mr. Kovacev worked closely with the IRS’s Large Business & International (LB&I) Division and top management of the Tax Division to shape litigation strategy on high-priority tax enforcement issues. These cases involved cross-border transactions, Section 482 disputes, Section 199 deductions, research credits, foreign tax credits, corporate reorganizations and acquisitions, and IP valuations, with claimed tax benefits ranging from $10 million to more than $1 billion.

Caitlin R. Tharp, Esq. | Steptoe & Johnson

Caitlin Tharp’s practice focuses on federal tax controversy and litigation matters, with experience in all stages of a tax dispute. Caitlin has litigated cases before the Tax Court, Court of Federal Claims, the US Court of Appeals for the District of Columbia Circuit, and federal district courts across the country. Her experience includes examining witnesses at trial and at deposition, as well as authoring scores of motions and briefs.

Caitlin has advised clients during Exam and advocated on behalf of clients at IRS Appeals. The subject areas of these disputes include challenges under the Administrative Procedure Act, the section 199 domestic production activities deduction, alternative energy tax credits, captive insurance, penalty abatement requests, and valuation questions.

Caitlin is a frequent speaker and writer on the intersection of tax and new technologies, focusing in particular on the application of existing tax rules to the metaverse.

Travis Thompson | Boutin Jones Inc.

Travis Thompson is a tax controversy attorney who has considerable experience handling all aspects of both Federal and state tax matters involving individuals, corporations, partnerships, limited liability companies, and trusts and estates. Travis develops innovative strategies to resolve civil tax examinations, administrative appeals, and collection matters with the IRS. He helps clients with IRS voluntary disclosures for previously undeclared foreign financial accounts and has successfully defended taxpayers against the assessment of tax penalties, including income tax, trust fund recovery, and foreign information return penalties. Travis also advises on the innocent spouse defense, cryptocurrency tax audits, Employee Retention Credit (“ERC”) tax audits, and other tax matters involving family planning and dissolution. He advocates for clients in the U.S. Tax Court, U.S. District Courts, U.S. Courts of Appeals, has drafted a petition for writ of certiorari to the United States Supreme Court, and represents clients in various white collar criminal defense cases.

Additionally, Travis advises clients in tax controversy matters involving the State of California. He represents clients against the California Franchise Tax Board, the California Department of Tax and Fee Administration, the Office of Tax Appeals, and the California State Board of Equalization. Travis also advises clients with tax questions about California residency. He has successfully represented individuals and businesses in civil harassment restraining order and workplace violence restraining order cases in the California Superior Court and Courts of Appeal.

Travis is a known expert in the subject of artificial intelligence and taxation and speaks and publishes regularly on how the IRS and foreign tax authorities utilize artificial intelligence (“A.I.”) in enforcement efforts. He advises attorneys, accountants, judges, government agencies, and businesses on responsible A.I., the ethical use of generative A.I, and A.I. bias. Travis is the current Chair of the Tax Practice & Technology Committee for the American Bar Association Section of Taxation. He is also a member of the American Bar Association’s A.I. Tax Force.

Before law school, he worked in business development for multiple Fortune 500 companies in the automotive and technology industries.

DAY 1: THURSDAY, JUNE 27, 2024

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

Voluntary compliance and enforcement of the tax law are at the heart of our tax system. Over the past several years, the IRS and DOJ have been challenged to come up with new and more efficient ways to ensure that all taxpayers pay the correct amount of tax. These panels provide an update on new developments and priorities across various divisions of the government.

Caroline D. Ciraolo, Esq., Partner, Kostelanetz, Washington, DC
Miri Forster, Esq., Partner and National Tax Controversy Leader, EisnerAmper, New York, NY

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

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

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

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

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

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

Break | 10:45am – 10:55am

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

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

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

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

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

Lunch | 12:15pm – 1:00pm

BREAK OUT SESSIONS | 1:00pm – 1:50pm

TRACK I

AUDITS OF EXEMPT ORGS AND PRIVATE FOUNDATIONS: TAX EXEMPT DOES NOT MEAN NO ENFORCEMENT!

The IRS is expanding its pursuit of high net-worth taxpayers with a renewed focus on the structures and transactions used to avoid and evade US tax obligations. To this end, the IRS Exempt Organizations Examinations program seeks to promote voluntary compliance by analyzing the operational and financial activities of exempt organizations and determining whether the organizations accurately filed required returns and reports. This panel of expert practitioners explores the complex tax and regulatory issues that apply to exempt organizations, explains common audit issues and the risks of noncompliance including substantial excise tax liabilities, and offers best practices in bringing exempt organizations into compliance.

Moderator: John Colvin, Esq., Partner, Colvin + Hallet, Seattle, WA
Meghan R. Biss, Esq., Partner, Loeb & Loeb, Washington, DC
Casey A. Lothamer, Esq., Area Counsel, Mid-Atlantic Region, Tax Exempt Government Entities, Internal Revenue Service, Washington, DC
Josh O. Ungerman, Esq., CPA, Partner, Meadows, Collier, Reed, Cousins, Crouch & Ungerman, Dallas, TX

Break | 1:50pm – 2:10pm

BREAK OUT SESSIONS | 2:10pm – 3:00pm

TRACK I

THE ROLE OF THE FORENSIC ACCOUNTANT

Forensic accountants use specialized techniques to uncover and explain financial and accounting anomalies and improper conduct. They are retained as consultants and testifying experts in a broad range of civil and criminal tax cases, serving as essential components of a legal team’s resolution strategy. This panel explores the role of the forensic accountant and how they can best work with tax practitioners in defending their client in a tax controversy.

Moderator: Walter Pagano, CPA, CFE, CFF, Partner, EisnerAmper, New York, NY
Kevin Hanff, Partner, Integritas3, Pensacola, FL
Susan Markel, CPA, Partner and Managing Director, AlixPartners, Washington, DC
Manny Muriel, MBA, EA, Partner, Bishop Muriel & Weirauch, East Islip, NY

Break | 3:00pm – 3:20pm

BREAK OUT SESSIONS | 3:20PM – 4:10PM

TRACK I

CRIMINAL INVESTIGATIONS—PLANNING FOR THE WORST TO ACHIEVE THE BEST RESULT

At the outset of a federal criminal tax investigation, the primary objective of a subject or target is generally universal – avoiding criminal charges. Defense counsel must pursue this objective while planning for an eventual indictment and a strong defense at trial. This panel of criminal tax trial lawyers shares their experience in managing the substantive and procedural issues that arise in criminal tax investigations to best prepare for the prosecution their clients hope to avoid.

Moderator: Guinevere M. Moore, Esq., Managing Member, Moore Tax Law Group, Chicago, IL
Sara G. Neill, Esq., Shareholder, Neill Schwerin Boxerman, PC, St. Louis, MO
Jeffrey A. Neiman, Esq., Partner, Marcus Neiman Rashbaum & Pineiro, Fort Lauderdale, FL
Rod J. Rosenstein, Esq., Partner, King & Spalding, Washington, DC

Break | 4:10pm – 4:30pm

BREAK OUT SESSIONS | 4:30PM – 5:30PM

TRACK I

IRA CLEAN ENERGY CREDITS AND ANTICIPATED ENFORCEMENT

The Inflation Reduction Act (“IRA”) is expected to drive the unprecedented growth in the clean energy industry. Under the IRA, certain businesses and tax-exempt entities are eligible for investment tax credits, production tax credits, manufacturing tax credits, and other tax credits to offset their federal taxes. Many of the credits may be transferred for cash to unrelated parties or are eligible for direct pay. With these tax benefits will come increased enforcement to ensure that taxpayers are not abusing the system. This panel addresses the various clean energy credits under the IRA, the eligibility and filing requirements, current and forthcoming Treasury and IRS guidance, special issues related to the transferability and elective pay rules, and what we can expect in future audits and investigations.

Moderator: Carina C. Federico, Esq., Partner, Crowell & Moring, Washington, DC
Shirley Chin, Esq., Head of Tax Insurance, WTW, San Francisco, CA
Ian M. Comisky, Esq., Partner, Fox Rothschild, Philadelphia, PA
Mark Nyman, Director, Corporate Issues/Credits, Internal Revenue Service, New York, NY
Philip J. Wilson, CPA, Office Managing Partner, Marcum, Costa Mesa, CA

DAY 2: FRIDAY, JUNE 28, 2024

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

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

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

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

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

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

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

Issuance of IRS collection notices have resumed and IRS collection efforts from high income non-filers and those with outstanding tax debt have brought in millions of dollars since FY 2023. This panel provides an update from IRS Collection on recent collection efforts, availability of new collection tools and expectations for the future that impacts every tax practice.

Moderator: Beverly Winstead, Esq., Principal, Law Office of Beverly Winstead, Baltimore, MD
Mary Beth Murphy, Director of Collections, North Atlantic Territory, Small Business/Self-Employed Division, Internal Revenue Service, Washington, DC

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

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

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

Break | 11:00am – 11:15am

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

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

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

Lunch | 12:15pm – 1:30pm

BREAK OUT SESSIONS | 1:30pm – 2:20pm

TRACK I

EMPLOYMENT TAXES—CIVIL AND CRIMINAL ENFORCEMENT

Employment taxes make up approximately 70% of all revenue collected by the IRS and employment tax non-compliance is a significant contributor to the annual Tax Gap. The IRS and Department of Justice continue to target this area with a variety of tools including audits, civil penalties, injunctions, and criminal investigations. This panel of experienced practitioners explores the government’s priorities in the employment tax space, the various enforcement efforts pursued, and strategies and best practices for navigating clients through these difficult waters.

Moderator: Christopher M. Ferguson, Esq., Partner, Kostelanetz, New York, NY
Megan E. Marlin, Esq., Principal, PwC, Washington, DC
Richard J. Sapinski, Esq., Partner, Sills Cummis & Gross PC, Newark, NJ
James A. Ulicny, Esq., Attorney, Office of Chief Counsel (Criminal Tax), Internal Revenue Service, New York, NY

Break | 2:20pm – 2:40pm

BREAK OUT SESSIONS | 2:40pm – 3:30pm

TRACK I

CORPORATE TRANSPARENCY ACT/NEW YORK LLC TRANSPARENCY ACT

The Corporate Transparency Act (CTA) creates new reporting requirements for companies created or registered to do business in the US. The CTA is effective January 1, 2024, and requires reporting companies to provide information on their company and its beneficial owners to the Financial Crimes Enforcement Network (FinCEN). Similarly, New York has passed its own NY LLC Transparency Act. This panel discusses who is subject to the reporting requirements, what information to report, the consequences for non-compliance, and how best to address recent cases (pending appeal) that have ruled the CTA is unconstitutional.
Moderator: Phillip Colasanto, Esq., Senior Associate, Withers Bergman, New York, NY
Yvonne R. Cort, Esq., Partner, Capell Barnett Matalon & Schoenfeld, Syosset, NY
Jay R. Nanavati, Esq., Partner, Kostelanetz, Washington, DC
Melissa L. Wiley, Esq., Partner, Lowenstein Sandler, Washington, DC

Break | 3:30pm – 3:50pm

BREAK OUT SESSIONS | 3:50pm – 4:50pm

TRACK I
ETHICS CREDIT: ARTIFICIAL INTELLIGENCE, CHATGPT & CIRCULAR 230

What exactly is Artificial Intelligence (AI) and how will AI impact tax practice in the future? Join us for an AI demonstration, while we explore the types of AI that are currently available and how they differ from each other. Panelists also address how the IRS is using AI in its enforcement efforts and what tax practitioners should be aware of under Circular 230 and the ABA Model Rules.

Moderator: Andrew Strelka, Esq., Counsel, Latham & Watkins, Washington DC
Benjamin Alarie, Esq., CEO, Blue J; Professor & Osler Chair of Business Law, University of Toronto, Toronto, Canada
Robert J. Kovacev, Esq., Member, Miller & Chevalier, Chartered, Washington, DC
Caitlin R. Tharp, Esq. Associate, Steptoe, Washington, DC
Travis W. Thompson, Esq., Counsel, Boutin Jones, Sacramento, CA