17th Annual Tax Controversy Forum 2025 – Track II (Presented by NYU School of Professional Studies) (Day 2)

Caroline D. Ciraolo, Esq., Partner | Kostelanetz

Caroline Ciraolo, former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division, is a partner with Kostelanetz LLP and founder of its Washington, D.C. office. Her practice focuses on federal and state civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, and representing individuals and entities in criminal tax investigations and prosecutions. She also serves as a consulting and testifying expert witness and an independent mediator in tax disputes.

Michael J. Desmond, Esq., Member and Co-Chair of Tax Controversy Group | Miller & Chevalier, Chartered

Michael Desmond’s practice covers a broad range of federal tax matters with a focus on administrative tax policy, tax controversy, and litigation. He represents clients in approaches to the Internal Revenue Service (IRS) and the U.S. Department of the Treasury (Treasury) on administrative rulemaking matters and matters relating to tax administration and enforcement, seeking clarity on the application of federal tax laws. He also represents clients before the examination divisions of the IRS, the IRS Independent Office of Appeals, and in the U.S. Tax Court, federal district courts, the Court of Federal Claims, and federal courts of appeal. Mike is described by clients in Chambers USA as “very smart, strategic, and knowledgeable of tax law,” “responsive and insightful,” noting that “[h]is knowledge of complex matters is incredibly valuable.”

Sharon Katz-Pearlman, Esq., Shareholder | 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.

Loren C. Ponds, Esq., Partner | Skadden, Arps, Slate, Meagher & Flom

Loren Ponds leverages her extensive tax policy experience to provide strategic counsel to clients across industries on a variety of legislative and regulatory issues. She also frequently advises on technical matters related to international tax, including controversy and transfer pricing.

Scott Levine, Esq., Former Deputy Assistant Secretary | International Tax Affairs

Scott Levine the Former Deputy Assistant Secretary (International Tax Affairs) and Tax partner in Baker McKenzie’s Tax Practice Group, based in the Firm’s DC office.
Prior to joining the Firm, Scott most recently served as the Deputy Assistant Secretary (International Tax Affairs) in the US Department of the Treasury, where he led the Office of Tax Policy’s work on international affairs, including regulations, treaties, and the OECD/G20 Inclusive Framework on BEPS negotiations on Pillar 1 and Pillar 2.

Joshua Odintz, Esq., Partner | Holland & Knight

Joshua D. Odintz is a tax attorney in Holland & Knight’s Washington, D.C., office. Mr. Odintz focuses on tax policy, tax controversy and tax planning matters. He is a co-leader of the Public Policy & Regulation Group’s Tax Policy Team.

Terry Lemons, Former Communications & Liaison Chief | Internal Revenue Service

Terry Lemons spent more than 26 years at the IRS in a variety of roles overseeing the agency’s communications efforts. Before retiring from the government in February, Lemons worked 11 years as the IRS Chief of Communications and Liaison, where he served as a principal advisor to the Commissioner and IRS leadership. In this role, he navigated some of the toughest communications scenarios in government while leading a 325-person team and overseeing the agency’s work with the tax professional community, Congress, the news media as well as internal communications to 100,000 employees.

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

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

Elizabeth Askey, Esq., Chief | IRS Independent Office of Appeals

Liz Askey is Chief of the Independent Office of Appeals at the Internal Revenue Service (IRS). In this role, she provides leadership and direction over nationwide programs designed to fairly and impartially resolve tax controversies without litigation on the behalf of the federal government and taxpayers.

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

Jennifer Breen represents domestic and multinational businesses, large partnerships, high-net-worth individuals, and family offices on tax controversy and Internal Revenue Service (IRS) administrative matters. She also counsels professional services firms, investment fund managers, and private equity firms on partnership tax issues. With decades of experience spanning government service, a “Big Four” public accounting firm, and in-house as the director of tax controversy for a large multinational corporation, Jennifer offers a rare perspective in her invaluable ability to see tax issues from multiple vantage points.

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

Judge Copeland was born in Colorado. She earned her Bachelor of Business Administration, cum laude, from the University of Texas at Austin, and her Juris Doctor from the University of Texas School of Law. A Certified Public Accountant (Texas, 1988), she was admitted to the State Bar of Texas in 1992.

Diana L. Erbsen, Esq., Partner | 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.

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

Dan’s legal practice focuses on tax and Title 31 (Bank Secrecy Act) controversy matters with the IRS and tax matters before certain state tax authorities. For over nineteen years, Dan served as an attorney for the Office of Chief Counsel of the Internal Revenue Service. As a former trial attorney and manager (supervisory trial attorney) with the Office of Chief Counsel and as a Special Assistant United States Attorney, Dan has had unique experience with tax controversy and tax administration. In February 2025, the American College of Tax Counsel elected Dan as a fellow (see press release) recognizing his experience practicing tax law.

Kaitlyn Loughner, Esq., CPA, Partner | Frost Law

Kaitlyn’s experience as a Certified Public Accountant and a tax attorney gives her a unique perspective on domestic and international tax compliance issues for individuals and businesses including streamlined compliance for individuals, corporations, partnerships, and limited liability companies. Kaitlyn handles cases with issues involving individual and corporate income tax, international tax compliance, IRS and State tax audits, tax relief and collection — including sales and use taxes, admissions and amusement tax, and withholding tax.

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

Guinevere Moore represents taxpayers in significant disputes with the Internal Revenue Service, the Department of Justice, Tax Division, and state taxing agencies. She is the Managing Member of Moore Tax Law Group, LLC, a tax controversy and tax litigation firm with an office in Chicago.

Carlos F. Ortiz, Esq., Partner | BakerHostetler

A seasoned trial attorney, recognized by Law360 as a “Legal Lion of the Week” and by AmLaw’s Litigation Daily as a “Litigator of the Week,” Carlos Ortiz focuses his practice on high-risk tax controversies, anti-corruption (Foreign Corrupt Practices Act (FCPA) and Foreign Extortion Protection Act (FEPA)), offshore tax issues, anti-money laundering, e-commerce fraud and healthcare fraud, as well as allegations of fraud against government agencies and financial institutions. He has extensive experience representing U.S.- and foreign-based corporations and individuals in the pharmaceutical, financial services, healthcare, aerospace, energy and telecommunications industries in connection with matters before enforcement and regulatory agencies, including the U.S. Department of Justice (DOJ), the Internal Revenue Service (IRS), the Securities and Exchange Commission (SEC) and various state attorneys general. Over his career in private practice, he has secured the declination of criminal charges for corporate and individual clients. On several occasions, he has prevented the referral of charges for the target of criminal tax investigations.

Rod J. Rosenstein, Esq., Partner | King & Spalding

As Deputy Attorney General under President Donald J. Trump, Rod J. Rosenstein supervised all Department of Justice components. He also held senior political appointments under Presidents George W. Bush and Barack Obama, as U.S. Attorney for Maryland from 2005 to 2017 and Principal Deputy Assistant Attorney General for the Tax Division from 2001 to 2005. A skilled trial and appellate lawyer, Rod personally represented the United States in 23 jury trials and argued 21 civil and criminal appeals in appellate courts and the Supreme Court. He helps clients with sensitive regulatory, enforcement and litigation challenges, including civil and criminal cases, congressional investigations, crisis management, national security and cyber issues, higher education inquiries, tax controversies, and compliance matters.

Don Fort, CPA, Director of Investigations | Kostelanetz

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

Guy Ficco, Chief, Criminal Investigation Division | Internal Revenue Service

Guy Ficco has been serving as the Chief of the IRS Criminal Investigation (CI) Division since April 1, 2024. A 29-year veteran of the IRS, Ficco began his career in 1995 as a student co-op in the New York Field Office. Over the years, he has held numerous leadership positions, including Deputy Chief of CI, Executive Director of Global Operations, and Special Agent in Charge of the Philadelphia Field Office. He is a Certified Fraud Examiner and holds a bachelor’s degree in business administration with a concentration in accounting from Dominican University in New York.

Ian M. Comisky, Esq., Partner | 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.

Jenny G. Sugar, Esq., Member | Moore & Van Allen

Jenny Sugar is a member of Moore & Van Allen’s Litigation group. She represents corporations and executives in white collar criminal and government enforcement investigations, proceedings, and trials.

As a federal prosecutor for more than two decades, Jenny investigated, prosecuted, and oversaw matters involving a broad range of complex financial crimes, including investment fraud, bank fraud, wire fraud, tax fraud, Ponzi schemes, money laundering, and abuse of government funding programs, as well as health care fraud matters.

Dean Zerbe, Esq. Partner | Zerbe, Miller, Fingeret, Frank & Jadav

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.

Randall M. Fox, Esq., Partner | Kirby McInerney

Randall M. Fox is a partner in our New York office who represents whistleblowers in False Claims Act and IRS, SEC, and CFTC matters about tax, healthcare, procurement, and investment frauds. He was named the Whistleblower Lawyer of the Year for 2021 by The Anti-Fraud Coalition.

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

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

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

In March 2020, Erin M. Collins was appointed by Secretary Mnuchin as the National Taxpayer Advocate and she now oversees the Office of the Taxpayer Advocate Service (TAS). She is the “Voice of the Taxpayer” within the IRS and before Congress. TAS serves as a “safety net” for taxpayers by advocating for resolution of individual and business taxpayer issues within the IRS. She identifies and works toward systemic changes 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 by being an independent voice inside the IRS. As the National Taxpayer Advocate, Erin testifies before the Senate Finance Committee, the U.S. House of Representatives Ways and Means Committee Oversight Subcommittee, and the Senate Appropriations Subcommittee on topics concerning tax administration and taxpayer rights.

E. Martin Davidoff, CPA, Esq., Partner-in-Charge | National Tax Controversy Practice, Prager Metis

E. Martin Davidoff, CPA, Esq., brings over 30 years of experience as both an accountant and attorney. He has authored 30 articles in CPA Magazine, serving as its IRS Representation Advisor. He is the founder of accounting and law firms dedicated primarily to taxes, tax advice, and tax preparation, with a mission to provide clients with peace of mind. Martin currently serves as the National Managing Partner of the Tax Controversy team at Prager Metis CPAs, LLC. For more information, please visit his websites.

Robert J. Fedor, Esq., Managing Member | Robert J. Fedor, Esq. LLC

Managing Member since 1995.

With over 35 years of experience in representing businesses and individuals before all types of Internal Revenue Service proceedings, whether it be administrative or before the United States Bankruptcy Court, the United States Tax Court, one of the United States District Courts or a U.S. Court of Appeals, Robert J. Fedor leads this 8-member firm with his expertise in tax and tax-related matters. Mr. Fedor’s experience has provided him with a vast understanding of tax-related issues, spanning from tax litigation, IRS collections, criminal tax defense, as well as other tax-related controversy matters.

The Hon. Jennifer E. Siegel, Special Trial Judge | United States Tax Court

Special Trial Judge Siegel holds a B.A. from Barnard College, an M.B.A. from the Drucker School of Management at Claremont Graduate University, a J.D. from the University of San Francisco School of Law, and an LL.M. in Taxation from New York University School of Law.

Moderator: Alan S. Lederman, Esq., Shareholder | Gunster 

Alan Lederman has considerable experience in most aspects of income tax planning and income tax controversies, including those related to international transactions.

Jorge M. Obén-Cuadros, Esq., International Tax Senior Counsel | Procopio

Jorge M. Obén-Cuadros, Esq. serves as International Tax Senior Counsel at Procopio, Cory, Hargreaves & Savitch LLP, operating from the firm’s Washington, D.C., office. With a robust background in international tax law, Mr. Obén-Cuadros provides strategic counsel on cross-border mergers and acquisitions, corporate structuring, financing, and reorganization transactions. His practice encompasses tax planning, controversy, and policy matters, assisting both U.S. and international clients in navigating complex tax landscapes.

Heather Fincher, Esq., Associate | Kostelanetz

Heather Fincher, Esq. is an Associate at Kostelanetz LLP in Washington, D.C., where she advises multinational businesses and high-net-worth individuals on U.S. federal income tax matters, with a particular focus on international tax planning and controversies. Her practice encompasses cross-border investments, cryptocurrency issues, mergers and acquisitions, joint ventures, and restructurings. She also regularly advises clients on special issues arising in international tax controversies.

Amie Colwell Breslow, Esq., Of Counsel | Jones Day

Amie Colwell Breslow, Esq. serves as Of Counsel in the Tax Practice at Jones Day’s Washington, D.C., office. With over two decades of experience in federal and international tax law, she advises multinational corporations on complex cross-border transactions, including mergers, acquisitions, spin-offs, and restructurings. Her expertise extends to specialized areas such as blockchain and digital assets, encompassing digital currency transactions, token offerings, and diverse investment structures.

Moderator: James Dawson, Esq., Partner | Holland & Knight

James P. Dawson, Esq. is a Partner at Holland & Knight LLP in West Palm Beach, Florida, where he specializes in tax litigation and controversy matters. With over three decades of experience, Mr. Dawson represents corporations and individual taxpayers in federal tax audits and litigation, including appearances before the U.S. Tax Court, U.S. Court of Federal Claims, and U.S. District Courts. His practice encompasses a wide range of industries, such as energy (nuclear, fossil, wind, and solar), real estate, and agriculture, and he has handled complex cases involving estate, income tax, and Report of Foreign Bank and Financial Accounts (FBAR) litigation.

Paul T. Butler, Esq., Associate Chief Counsel (Procedure & Administration), Office of Chief Counsel | Internal Revenue Service

Paul T. Butler, Esq. serves as the Associate Chief Counsel (Procedure & Administration) at the Internal Revenue Service (IRS) Office of Chief Counsel in Washington, D.C. In this capacity, he leads a division responsible for providing legal guidance on a broad spectrum of procedural and administrative tax matters.

Kate Kraus, Esq., Partner | Covington & Burling

Kate Kraus, Esq. is a Partner at Covington & Burling LLP in Los Angeles, where she specializes in tax planning, structuring, and controversy matters. With over two decades of experience, she is nationally recognized for her expertise in partnership tax, particularly the rules enacted under the Bipartisan Budget Act of 2015 (BBA).

Jennifer M. Black, Esq., Managing Director | Citrin Cooperman

Jennifer M. Black, Esq. is a Managing Director in the National Tax Office at Citrin Cooperman Advisors LLC, based in Washington, D.C. She leads the firm’s Tax Procedure & Controversy practice, focusing on complex federal tax matters, particularly those involving partnerships and administrative procedures.

Moderator: Stephen Josey, Esq., Counsel | Vinson & Elkins

Stephen Josey is a Counsel in the Tax Controversy and Litigation practice at Vinson & Elkins LLP in New York. He specializes in representing taxpayers in civil and criminal matters involving the Internal Revenue Service (IRS), the New York State Department of Taxation and Finance, and the United States Department of Justice Tax Division. His extensive experience encompasses audits, administrative investigations, Tax Court matters, tax refund suits, summons enforcement, collection actions, and bankruptcy disputes involving tax claims. Additionally, he has litigated tariff-related disputes in the U.S. Court of International Trade and the U.S. Court of Appeals for the Federal Circuit .

Christopher Slade, Esq., Partner | Aird & Berlis

Christopher Slade is a Partner at Aird & Berlis LLP in Toronto, Canada, specializing in tax litigation and dispute resolution. He is recognized for his expertise in handling complex tax controversies and has been acknowledged as a leading practitioner in his field.

Philip J. Wilson, CPA, Managing Director | CBIZ

Philip J. Wilson, CPA, is a Managing Director at CBIZ, Inc., based in the firm’s Costa Mesa, California office. With over 30 years of experience in CPA and business advisory services, including a tenure as an IRS Revenue Agent, he specializes in assisting individuals and businesses in resolving tax controversies with the Internal Revenue Service. His clientele includes a diverse range of corporations and high-net-worth individuals. Before joining CBIZ, Mr. Wilson was a founding partner at WilsonMorgan LLP in Irvine, where he managed all tax compliance, consulting, and controversy engagements. He possesses substantial expertise in real estate tax structuring for both commercial and residential developers, as well as in various other industries.

Parul Jain, Esq., CPA, Head of International Tax Practice | Nishith Desai Associates

Parul Jain, Esq., CPA, is a distinguished legal and tax professional serving as the Head of the International Tax Practice at Nishith Desai Associates in New Delhi, India. With nearly two decades of experience, she specializes in cross-border taxation, mergers and acquisitions (M&A), group reorganizations, and fund formation strategies. Her expertise encompasses advising multinational corporations, private equity, and venture capital funds on structuring investments into India, including the establishment of onshore and offshore fund platforms.

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

Carina C. Federico, Esq., is a Partner at Crowell & Moring LLP in Washington, D.C., specializing in tax litigation and controversy. She advises clients on complex tax issues, including transfer pricing, investment tax credits, research and experimentation credits, and energy credits. Her practice encompasses all stages of tax disputes, from IRS audits to appellate court litigation. Carina has represented clients in various forums, including the U.S. Tax Court, federal district courts, and the IRS Office of Appeals.

Harry Ballan, Esq., Head of Tax Insurance | Munich Re

Harry Ballan is the Head of Tax Credit Insurance at Munich Re, based in New York. In this role, he leads a team that provides insurance solutions to protect investors, developers, and buyers of clean energy tax credits—such as Investment Tax Credits (ITCs) and Production Tax Credits (PTCs)—against challenges or recapture by U.S. tax authorities. This offering is particularly pertinent in light of the U.S. Inflation Reduction Act, which has spurred significant investments in renewable energy projects. Munich Re’s tax credit insurance aims to mitigate risks associated with the transferability and eligibility of these credits, thereby enhancing the financial stability of clean energy ventures.

Shirley Chin, Esq., Head of Tax Insurance | Willis Towers Watson

Shirley Chin, Esq., CPA, serves as the Head of Tax Insurance at WTW (Willis Towers Watson) in San Francisco, California. With over 25 years of legal experience across the private, public, government, and nonprofit sectors, she brings a wealth of expertise to her role.

Sharyn M. Fisk, Esq., Associate Professor | Cal Poly Pomona

Sharyn M. Fisk, Esq., is an Associate Professor in the Accounting Department at California State Polytechnic University, Pomona (Cal Poly Pomona). She specializes in federal and California taxation, tax controversies, tax litigation, and tax procedure.

Amish Shah, Esq., Partner | Holland & Knight

Amish Shah, Esq., is a Partner at Holland & Knight LLP in Washington, D.C., where he specializes in tax law with a focus on energy, environmental, and clean energy sectors.

Moderator: Megan E. Marlin, Esq., Principal | PricewaterhouseCoopers

Megan E. Marlin, Esq., LL.M., is a Principal at PwC (PricewaterhouseCoopers) in Washington, D.C., specializing in employment tax and rewards. She leads PwC’s Employment Tax & Rewards practice, advising public and private companies on a wide range of tax matters, including executive compensation, employee benefits, and employment tax compliance. Her expertise encompasses both domestic and international tax issues, helping clients navigate complex regulatory environments.

Mary B. Hevener, Esq., Partner | Morgan, Lewis & Bockius

Mary B. “Handy” Hevener helps US and multinational enterprises minimize corporate payroll taxes at both the federal and state levels, and maximize benefits–related tax deductions. She focuses her practice on the tax and information reporting treatment of employee and independent contractor benefits outside qualified retirement plans, including stock options and other stock-based compensation; executive income deferrals; golden parachutes; and fringe benefits that range from health and life insurance, to employee loans, cars, planes, and prizes.

Brian C. McManus, Esq., Partner | Latham & Watkins

Brian C. McManus, Esq., is a Partner at Latham & Watkins LLP, based in the firm’s Boston office. He serves as the Chair of the Boston Tax Department and is the Global Co-Chair of the firm’s Tax Controversy Practice. Mr. McManus is widely recognized as one of the nation’s leading tax litigators, advising companies and high-net-worth individuals in all phases of civil and criminal tax disputes. His practice encompasses a broad spectrum of federal and state taxation issues, with a particular emphasis on cross-border and international tax matters, sophisticated corporate transactions, enterprise and asset valuations, transfer pricing, partnerships, tax-exempt organizations, oil and gas taxation, tax shelters, promoter penalty defense, and cryptocurrency. He also frequently handles sensitive tax matters involving allegations of fraud and potential criminal tax charges, as well as voluntary disclosures of domestic and offshore filing errors.

Robert J. Kovacev, Esq., Member | Miller & Chevalier, Chartered

Robert J. Kovacev, Esq., is a Member of Miller & Chevalier Chartered in Washington, D.C., specializing in federal tax controversy and litigation. With over two decades of experience, he represents clients in high-profile tax disputes against the Internal Revenue Service (IRS) at both the administrative level and in litigation. His practice encompasses international tax, transfer pricing, research tax credits, Section 199 domestic production activities deductions, alternative energy tax credits, and economic substance doctrines. Mr. Kovacev has served as lead counsel in significant cases before the U.S. Tax Court, federal district courts, and appellate courts. Notably, he has represented clients in disputes involving claimed tax benefits ranging from $10 million to over $1 billion.

Moderator: Sharon L. McCarthy, Esq., Partner | Kostelanetz

Sharon L. McCarthy, Esq., is a Partner at Kostelanetz LLP in New York City, specializing in white-collar criminal defense and civil and criminal tax controversies. She has extensive experience representing individuals and corporations in complex legal matters, including securities fraud, tax fraud, mail and wire fraud, antitrust violations, and public corruption. Notably, she achieved a full acquittal for Denis Field, former CEO of BDO Seidman, in a major tax shelter trial described by the government as the largest criminal tax fraud in history.

Nina Marino, Esq., Partner | Kaplan Marino

Nina Marino, Esq., is a founding partner of Kaplan Marino, PC, a Los Angeles-based law firm renowned for its white-collar and complex criminal defense practice. Since co-founding the firm in 1998 with Richard Kaplan, she has devoted her career exclusively to defending individuals facing serious criminal allegations, including healthcare fraud, public corruption, money laundering, international extradition, and cybercrime. Her clientele comprises senior executives, public figures, and business professionals both domestically and internationally.

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

Jeffrey A. Neiman, Esq., is a founding partner at Marcus Neiman Rashbaum & Pineiro LLP (MNR Law Firm) in Fort Lauderdale, Florida. He is a seasoned trial attorney specializing in white-collar criminal defense, tax controversy, government enforcement actions, and complex civil litigation.

Matt Mueller, Esq., Partner | Fogerty Mueller Harris

Matt Mueller is a former federal prosecutor and experienced trial lawyer. He represents individual and corporate clients in Florida and across the nation in tax, securities, and health care matters, regulatory enforcement actions, grand jury investigations, whistleblower matters, and civil litigation.

Moderator: Alexander L. Reid, Esq., Partner | BakerHostetler

Alexander L. Reid, Esq., is a Partner at BakerHostetler in Washington, D.C., where he leads the firm’s national Tax-Exempt Organizations and Charitable Giving team. With a focus on tax law, governance, and public policy, he advises a diverse range of tax-exempt entities—including colleges, universities, health systems, private foundations, arts organizations, and trade associations. His work encompasses planning, structuring, governance, investigations, tax compliance, and transactional matters, often serving as outside general counsel to these organizations.

Kelley C. Miller, Esq., Partner | Reed Smith

Kelley C. Miller, Esq., is a Partner at Reed Smith LLP in Washington, D.C., specializing in federal and state tax planning, estate and gift planning, and tax controversy matters. She represents Fortune 25 companies, billion-dollar privately held entities, and high-net-worth individuals in complex tax issues, including audits, administrative appeals, and litigation before the U.S. Tax Court and federal courts. Her practice encompasses civil and criminal tax implications, with a focus on closely held entities and tax-exempt organizations.

Casey A. Lothamer, Esq., Area Counsel, Mid-Atlantic Region, Tax Exempt Government Entities | Internal Revenue Service

Casey A. Lothamer, Esq., serves as Area Counsel for the Mid-Atlantic Region within the Tax Exempt and Government Entities (TEGE) division of the Internal Revenue Service (IRS). In this capacity, she provides legal guidance on a broad spectrum of issues affecting tax-exempt organizations, including compliance, governance, and regulatory matters.

Rachel Leiser Levy, Esq., Former Associate Chief Counsel, Employee Benefits, Exempt Organizations, and Employment Taxes, Office of Chief Counsel | Internal Revenue Service

Rachel Leiser Levy, Esq., is the former Associate Chief Counsel for Employee Benefits, Exempt Organizations, and Employment Taxes (EEE) at the Internal Revenue Service (IRS) Office of Chief Counsel. In this role, she led the EEE division, which provides published guidance, field support, and taxpayer advice on a wide array of topics, including qualified retirement plans, health and welfare and other employee benefits, executive compensation and fringe benefits, tax-exempt entities, employment tax, state and local governments, and Indian tribal governments.

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

Meghan R. Biss, Esq., is a Partner at Loeb & Loeb LLP in Washington, D.C., specializing in nonprofit and tax-exempt organizations law. She represents a diverse array of clients, including private foundations, national and foreign charities, social welfare organizations, colleges and universities, government agencies, lobbying and political organizations, and trade associations.

DAY 1, THURSDAY, JUNE 26, 2025

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

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

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

Voluntary compliance and enforcement of the tax law are at the heart of our tax system. Over the past several years, the Internal Revenue Service (IRS) and Justice Department (DOJ) have been pursuing new and more efficient ways to ensure that all taxpayers pay the correct amount of tax. In recent weeks, however, the future and efficacy of those programs have been called into question as resource constraints are being imposed across the federal government. These panels, including three afternoon breakout sessions, provide a comprehensive update on developments and priorities across various functions of the Treasury Department, Justice Department Tax Division and IRS relating to enforcement of and compliance with our Nation’s tax laws.

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

Michael J. Desmond, Esq., Member and Co-Chair of Tax Controversy Group, Miller & Chevalier, Chartered, Washington, DC

WHAT’S NEXT FOR THE IRS? A BUDGET AND POLICY PERSPECTIVE | 8:30am – 9:20am

At our 2024 program, the IRS’ Operating Division Commissioners provided an update on a new leadership structure at the IRS designed to align its enforcement priorities with a surge in funding provided for under the Inflation Reduction Act. That enforcement focus has since flipped, with a turnover in leadership, a major curtailment of funding and staff, and projections for further material resource reductions. The future of IRS enforcement is now tied up with broader legislative priorities, including extension of the individual and various expiring business provisions of the Tax Cuts and Jobs Act and an uncertain future for the IRS. Meanwhile, the rest of the world is rapidly moving forward with implementation of the Organization for Economic Co-operation and Development’s (OECD) Global Anti-Base Erosion Rules (GloBE) (Pillar 2), with the United States sitting on the sidelines for the moment on these global tax initiatives. Our panel of experts all work at the intersection of tax administration and policy and they provide insight on what the future might hold for tax enforcement, both domestically and around the world.

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

Loren C. Ponds, Esq., Partner, Skadden, Arps, Slate, Meagher & Flom, Washington, DC

Scott Levine, Esq., Former Deputy Assistant Secretary, International Tax Affairs, Washington, DC

Joshua Odintz, Esq., Partner, Holland & Knight, Washington, DC

Terry Lemons, Former Communications & Liaison Chief, Internal Revenue Service, Washington, DC

Break | 9:20am – 9:30am

UPDATE FROM THE IRS INDEPENDENT OFFICE OF APPEALS | 9:30am – 9:55am

The IRS Independent Office of Appeals (Appeals) has always served a critical role in resolving tax disputes short of litigation, considering hazards of litigation for taxpayers and the IRS alike. Over the past two years, Appeals has been calibrating a renewed focus on alternative dispute resolution (ADR) procedures as a tool to complement its traditional conference procedures. In the current resource constrained environment, with a large inventory of complex cases pending in Exam, Appeals and in litigation, Appeals in general and ADR programs in particular are likely to play an increasingly important role in minimizing delay in dispute resolution. The Chief of IRS Appeals has been invited to give her perspective on ADR and to provide an update on Appeals activities in general.

Moderator: Emily P. Hughes, PC, Esq., Partner, Kirkland & Ellis, Washington, DC

Elizabeth Askey, Esq., Chief, IRS Independent Office of Appeals, Washington, DC (invited)

Break | 9:55am – 10:05am

UPDATE FROM THE U.S. TAX COURT AND THE IRS OFFICE OF CHIEF COUNSEL | 10:05am – 10:50am

The Tax Court and IRS Office of Chief Counsel sit at the center of tax controversy, with more than 25 thousand pending cases that range from multibillion dollar transfer pricing disputes to collection due process matters with relatively small amounts at stake but often presenting important questions of law. Decisions from the Tax Court have broad consequences across the federal tax system. This panel provides insight into cases pending with the Tax Court and matters being worked by Chief Counsel that may be on their way to the Court. The Deputy Chief Counsel (Operations) has also been invited to provide an update on Counsel activities including litigation in Tax Court, prospects for case resolution in a resource constrained environment and the role of field counsel attorneys in advising Exam, Appeals and other IRS functions

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

The Hon. Elizabeth A. Copeland, Judge, United States Tax Court, Washington, DC (invited)

Audrey M. Morris, Esq., Deputy Chief Counsel (Operations), Office of Chief Counsel, Internal Revenue Service, Washington, DC (invited)

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

Break | 10:50am – 11:00am

PSYCHOLOGY AND TAX ENFORCEMENT | 11:00am – 12:00pm

Psychological issues are an often-overlooked factor in many tax disputes, particularly but not only for individual taxpayers. These issues often create or magnify tax compliance problems such as non-filing, non-payment, and an impaired ability to interact with the IRS to resolve or address a tax dispute. Properly explained and understood, these issues can also provide a basis for penalty relief, late filing relief, late election relief, and other relief. This panel considers the impact of psychological issues on tax compliance and enforcement, including the use of experts.

Moderator: Daniel N. Price, Esq., Law Offices of Daniel N. Price, San Antonio, TX

Kaitlyn Loughner, Esq., CPA, Partner, Frost Law, Annapolis, MD

Guinevere M. Moore, Esq., Managing Member, Moore Tax Law Group, Chicago, IL

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

Russell Wade, Psychotherapist, Russell l Wade, ACSW LICSW, Washington, DC

Lunch | 12:00pm – 1:00pm

BREAK OUT SESSIONS | 1:00pm – 1:50pm

TRACK II

THE ROLE OF US TRADE AGREEMENTS IN TAX DISPUTES

The number of Bilateral Investment Treaties (BITs) and Free Trade Agreements (FTAs) is comparable to the number of tax treaties. Many of these BITs and FTAs give investors from one country the right to recover a tax collected from their companies in the other, host, country, if such tax collection is determined by an arbitration panel to constitute an indirect expropriation or otherwise violate certain standards of fairness. However, considerable costs and potential roadblocks must be considered. This panel reviews the potential use of BITs and FTAs for taxes imposed by foreign governments on US-owned foreign companies (including taxes scheduled to be imposed for 2026 under the OECD Pillar 2 Undertaxed Profits Rule, which taxes are a principal target of the current Administration). The panel also considers the potential use of BITs and FTAs for US taxes imposed by the IRS on foreign-owned US companies.

Moderator: Alan S. Lederman, Esq., Shareholder, Gunster, Fort Lauderdale, FL

Jorge M. Obén-Cuadros, Esq., International Tax Senior Counsel, Procopio, Washington, DC

Heather Fincher, Esq., Associate, Kostelanetz, Washington, DC

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

Break | 1:50pm – 2:10pm

BREAK OUT SESSIONS | 2:10pm – 3:00pm

TRACK II

PARTNERSHIP AUDITS AND LITIGATION UNDER THE BBA

The Bipartisan Budget Act (“BBA”) was signed into law on November 2, 2015, replacing the audit and collection procedures for partnerships under the Tax Equity and Fiscal Responsibility Act of 1982 (“TEFRA”) for tax years generally beginning in 2018. BBA audits have been on the rise with revenue agents and tax professionals working together to navigate jurisdictional issues, notice requirements, imputed underpayment computations and adjustments, push out elections and litigation of BBA matters in court. This panel explains the centralized partnership audit regime and addresses recent partnership audit trends, notices to expect from the IRS, actions to take during the audit, methods to challenge proposed adjustments, and the impact on the individual partners.

Moderator: James Dawson, Esq., Partner, Holland & Knight, West Palm Beach, FL

Paul T. Butler, Esq., Associate Chief Counsel (Procedure & Administration), Office of Chief Counsel, Internal Revenue Service, Washington, DC (invited)

Kate Kraus, Esq., Partner, Covington & Burling, Los Angeles, CA

Jennifer M. Black, Esq., Managing Director, Citrin Cooperman, Washington, DC

Break | 3:00pm – 3:20pm

BREAK OUT SESSIONS | 3:20pm – 4:10pm

TRACK II

CROSS BORDER INFORMATION GATHERING AND DISCOVERY

Cases raising cross-border issues often raise complex substantiation issues when documents or other information located abroad are needed to examine or sustain a return reporting position. This panel discusses offshore information gathering techniques available to the IRS including FATCA research, exchange of information requests, consent directives and letters of request. While more broadly available to the IRS than to taxpayers, it can be advantageous for taxpayers to encourage the IRS to pursue these techniques, including in cases where the taxpayer may carry the burden of proof.

Moderator: Stephen Josey, Esq., Counsel, Vinson & Elkins, New York, NY

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

Philip J. Wilson, CPA, Managing Director, CBIZ, Costa Mesa, CA

Parul Jain, Esq., CPA, Head of International Tax Practice, Nishith Desai Associates, New Delhi, India

Break | 4:10pm – 4:30pm

BREAK OUT SESSIONS | 4:30pm – 5:30pm

TRACK II

SUBSTANTIATING AND DEFENDING AUDITS OF IRA CLEAN ENERGY CREDITS

The clean energy credits enacted in and expanded under the Inflation Reduction Act present a number of novel technical issues, ranging from qualification requirements to assignability, prevailing wage and apprenticeship requirements. These novel aspects of the credits will present challenges for taxpayers (including assignees) and the IRS alike as they come into focus in examinations. This panel provides insight on issues that are being raised in clean energy credit audits and discusses steps taxpayers and practitioners can take to prepare for and manage the audits.

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

Harry Ballan, Esq., Head of Tax Insurance, Munich Re, New York, NY

Shirley Chin, Esq., Head of Tax Insurance, WTW, San Francisco, CA

Sharyn M. Fisk, Esq., Associate Professor, Cal Poly Pomona, Pomona, CA

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

DAY2, FRIDAY, JUNE 27, 2025

TAX COMPLIANCE AND ENFORCEMENT UPDATE: PART II | 8:30am – 8:55am

UPDATE FROM THE TAX DIVISION, US DEPARTMENT OF JUSTICE

The Tax Division is going through a historic change in leadership and is the subject of ongoing discussions on its role and placement in tax administration. Meanwhile, along with other federal agencies, the Tax Division is dealing with a curtailment of resources while also absorbing an increase in the number of tax cases filed in refund, bankruptcy and other courts around the country. The Tax Division is also responsible for representing the United States in the various courts of appeal on cases involving tax at a dynamic time for important issues such as the standard for review of agency rulemaking. This interview provides an update on these and other important topics.

Moderator: Rod J. Rosenstein, Esq., Partner, King & Spalding, Washington, DC

Representative, Tax Division, US Department of Justice, Washington, DC (to be invited)

Break | 8:55am – 9:05am

CRIMINAL TAX ENFORCEMENT UPDATE | 9:05am – 10:05am

Criminal tax cases impact tax enforcement and administration far beyond the cases charged and tried every year, sending a signal to taxpayers and practitioners of areas of compliance that are a particular focus for the IRS. In a resource constrained environment, this signal could be more important than ever, as practitioners gage the future of tax compliance and enforcement. This panel provides inside perspective on the status of IRS criminal investigations and what to expect going forward.

Moderator: Don Fort, CPA, Director of Investigations, Kostelanetz, Washington, DC

Guy Ficco, Chief, Criminal Investigation Division, Internal Revenue Service, Washington, DC (invited)

Representative, Tax Division, US Department of Justice, Washington, DC (to be invited)

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

Jenny G. Sugar, Esq., Member, Moore & Van Allen, Charlotte, NC

Break | 10:05am – 10:20am

IRS WHISTLEBLOWER OFFICE UPDATE | 10:20am – 10:45am

With the enactment of recent changes to 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 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 that 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 (invited)

Randall M. Fox, Esq., Partner, Kirby McInerney, New York, NY

Break | 10:45am – 10:55am

TAXPAYER ADVOCATE UPDATE | 10:55am – 11:25am

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 by the pandemic and now facing the challenge of a resource constrained environment), Collins and her team continue their dual focus on addressing systemic issues (of which there are many) and handling individual taxpayer cases (of which there are many more). Hear about the lessons learned over Collins’ past five years in the role and her vision for the future of the Taxpayer Advocate Service.

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

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

Break | 11:25am – 11:40am

IRS COLLECTION UPDATE | 11:40am – 12:20pm

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: E. Martin Davidoff, CPA, Esq., Partner-in-Charge – National Tax Controversy Practice,

Prager Metis, Cranbury, NJ

Robert J. Fedor, Esq., Managing Member, Robert J. Fedor, Esq., Cleveland, OH

The Hon. Jennifer E. Siegel, Special Trial Judge, United States Tax Court, Washington, DC (invited)

Lunch | 12:20pm – 1:30pm

BREAK OUT SESSIONS | 1:30pm – 2:20pm

TRACK II

EMPLOYMENT TAXES—CIVIL AND CRIMINAL ENFORCEMENT

Employment taxes (including, for the purpose, income tax withholding) make up approximately 70 percent 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: Megan E. Marlin, Esq., Principal, PwC, Washington, DC

Mary B. Hevener, Esq., Partner, Morgan, Lewis & Bockius, Washington, DC

Brian C. McManus, Esq., Partner, Latham & Watkins, Boston, MA

Robert J. Kovacev, Esq., Member, Miller & Chevalier, Chartered, Washington, DC

Break | 2:20pm – 2:40pm

BREAK OUT SESSIONS | 2:40pm – 3:30pm

TRACK II

TALES FROM THE TRENCHES: CRIMINAL TAX TRIALS

The IRS and Justice Department are highly selective in the tax cases that proceed to indictment and most of the cases that do get indicted are resolved short of trial. Accordingly, the criminal cases that go to trial often involve unique circumstances that give a window for practitioners into enforcement challenges and priorities. This panel of experienced trial lawyers discusses their recent experiences in taking criminal tax cases to trial.

Moderator: Sharon L. McCarthy, Esq., Partner, Kostelanetz, New York, NY

Nina Marino, Esq., Partner, Kaplan Marino, Los Angeles, CA

Jeffrey A. Neiman, Esq., Partner, Marcus Neiman Rashbaum & Pineiro, Fort Lauderdale, FL

Matt Mueller, Esq., Partner, Fogerty Mueller Harris, Tampa, FL

Break | 3:30pm – 3:50pm

BREAK OUT SESSIONS | 3:50pm – 4:50pm

TRACK II

TAX ISSUES FOR TAX EXEMPTS: ENFORCEMENT ISSUES FOR EXEMPT ORGANIZATIONS

Examinations of tax-exempt organizations and enforcement activity in this area in general raise unique challenges and considerations. These arise, in part, due to the unique substantive issues involved in the organization and operation of exempt organizations, presenting challenges for the IRS and taxpayers alike. This panel of expert practitioners reviews issues that often arise in the examination of exempt organizations and discusses best practices in managing these examinations.

Moderator: Alexander L. Reid, Esq., Partner, BakerHostetler, Washington, DC

Kelley C. Miller, Esq., Partner, Reed Smith, Washington, DC

Casey A. Lothamer, Esq., Area Counsel, Mid-Atlantic Region, Tax Exempt Government Entities, Internal Revenue Service, Washington, DC (invited)

Rachel Leiser Levy, Esq., Former Associate Chief Counsel, Employee Benefits, Exempt Organizations, and Employment Taxes, Office of Chief Counsel, Internal Revenue Service, Washington, DC (invited)

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