Criminal Tax Day Conference 2021

Sarah V. Spodick, Esq.
Michael Sardar, Esq.
Frank Agostino, Esq.
Sharon McCarthy, Esq.
Barbara Kaplan, Esq.
Jeffrey Sklarz, Esq.
Walter Pagano, CPA, CFE,
Jay Nanavati, Esq.
Zhanna A. Ziering, Esq.
Eric L. Green
Sarah Paul, Esq.
John D. (Don) Fort,
Bryan Skarlatos, Esq.
Sara G. Neill, Esq.
Damon Rowe, Director
Caroline D. Ciraolo, Esq.
Sareena Sawhney, MBA, CFE,
Anastasia King
Jeffrey Miller, Supervisory
Sarah V. Spodick, Esq. | Director, Low Income Taxpayer Clinic, Quinnipiac Law School
Michael Sardar, Esq. | Kostelanetz & Fink, LLP, New York, NY
Frank Agostino, Esq. | Agostino & Associates, PC, Hackensack, NJ
Sharon McCarthy, Esq. | Kostelanetz & Fink, LLP, New York, NY
Barbara Kaplan, Esq. | Greenberg Traurig, New York, NY
Jeffrey Sklarz, Esq. | Green & Sklarz LLC, New Haven, CT
Walter Pagano, CPA, CFE, | Eisner Amper, New York, NY
Jay Nanavati, Esq. | Kostelanetz & Fink, LLP, Washington, DC
Zhanna A. Ziering, Esq. | Caplin Drysdale, New York, NY
Eric L. Green | Green & Sklarz LLC, New Haven, CT
Sarah Paul, Esq. | Eversheds Sutherland, New York, NY
John D. (Don) Fort, | Kostelanetz & Fink, LLP, Washington, DC (former Chief of the Internal Revenue Service’s Criminal Investigation (CI) Division)
Bryan Skarlatos, Esq. | Kostelanetz & Fink, LLP, New York, NY
Sara G. Neill, Esq. | Capes Sokol, St. Louis, MO
Damon Rowe, Director | Fraud Enforcement Office, Internal Revenue Service, Washington, DC
Caroline D. Ciraolo, Esq. | Kostelanetz & Fink LLP, Washington, DC
Sareena Sawhney, MBA, CFE, | Withum, Smith & Brown, PC, New York, NY
Anastasia King | Asst. United States Attorney, New Haven, CT
Jeffrey Miller, Supervisory | Special Agent, IRS Criminal Investigation, White Plains, NY

On-Demand: June 4, 2021

Criminal Tax Day Conference 2021
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Program Summary

Join nationally recognized experts and government officials to learn everything you ever wanted to know about criminal tax and how to protect your clients from themselves!

This course is co-sponsored with myLawCLE.

Key topics to be discussed:

  • What’s New in Criminal Tax.
  • Parallel Civil & Criminal Investigations
  • PPP Loan Fraud.
  • The IRS’s Use of Artificial Intelligence in Criminal Tax Cases
  • Non-Filers
  • The Criminal Investigation Part 1: Inside the Defense Room
  • The Criminal Investigation Part 2: Meeting with the Government

Date/Time: June 4, 2021

  • 8:00 am – 5:00 pm Eastern
  • 7:00 am – 4:00 pm Central
  • 6:00 am – 3:00 pm Mountain
  • 5:00 am – 2:00 pm Pacific

Choose a format:

Live Video Broadcast/Re-Broadcast: Watch Program "live" in real-time, must sign-in and watch program on date and time set above. May ask questions during presentation via chat box. Qualifies for "live" CLE credit.
On-Demand Video: Access CLE 24/7 via on-demand library and watch program anytime. Qualifies for self-study CLE credit. On-demand versions are made available 5 business days after the original recording date and are view-able for up to one year.

Closed-captioning available


Michael Sardar, Esq_Kostelanetz & Fink, LLP, New York, NY_myLawCLEMichael Sardar, Esq | Kostelanetz & Fink, LLP, New York, NY

Michael Sardar has extensive experience on a wide range of tax controversy and white collar criminal defense matters. Mr. Sardar represents clients in all stages of civil and criminal tax controversies before the Internal Revenue Service (IRS), state tax authorities, the Department of Justice, and local prosecutors.

Mr. Sardar also represents and advises taxpayers facing audits and investigations of noncompliance with the IRS’ foreign bank and asset reporting requirements, utilizing his skill, creative thinking, and deep knowledge of the law in this area. In addition, Mr. Sardar has a great deal of experience representing corporate and individual taxpayers making voluntary disclosures of unreported income to the IRS and state tax authorities. He has also represented scores of clients with unreported foreign assets, enabling the repatriation of over half a billion dollars of offshore assets through the IRS’ Offshore Voluntary Disclosure Program and the Streamlined Compliance Procedures.

Mr. Sardar represents clients in criminal tax investigations, in various white collar criminal matters, and in connection with internal investigations regarding corporate and entity noncompliance. Mr. Sardar also represents taxpayers in New York State and City residency audits and investigations, including those before the New York State Attorney General’s Office.

Mr. Sardar joined Kostelanetz & Fink in 2009 and was named partner in January 2019. Prior to joining Kostelanetz & Fink, Mr. Sardar was an attorney with Heller Ehrman LLP, where his practice was focused on transactional tax matters. Mr. Sardar has also advised many nonprofit organizations on federal and state tax issues including general tax exemption and Unrelated Business Income Tax (UBIT).

Mr. Sardar is Co-Chair of the Federal Bar Association (FBA) Section on Taxation, New York Chapter. He also serves as Co-Chair of the Subcommittee on Offshore Enforcement of the ABA Committee on Civil and Criminal Tax Penalties. He is a former Vice-Chair of the New York County Lawyers’ Association (NYCLA) Taxation Committee. Mr. Sardar lectures and writes frequently on tax controversy topics, including foreign asset reporting and non-compliance.

Mr. Sardar graduated summa cum laude from Baruch College in 2004 with a bachelor’s degree in Business Administration and received his law degree from Cornell University Law School in 2007.


Frank Agostino, Esq_Agostino & Associates, PC, Hackensack, NJ_myLawCLEFrank Agostino, Esq | Agostino & Associates, PC, Hackensack, NJ

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.


Sharon McCarthy, Esq._Kostelanetz & Fink, LLP, New York, NY_myLawCLESharon McCarthy, Esq., | Kostelanetz & Fink, LLP, New York, NY

Sharon L. McCarthy, a Fellow of the American College of Trial Lawyers, has extensive experience representing individuals and corporations in white-collar criminal matters as well as civil and criminal tax controversies.
Her cases have included government investigations of: tax fraud; mail and wire fraud, including theft of honest services; accounting fraud; failure to file tax returns; criminal antitrust violations; securities fraud, including insider trading and market manipulation; bank fraud; construction fraud relating to Minority and Women Owned Business Enterprise (MWBE) certification; and attorney misconduct.

Ms. McCarthy serves as the Pro Bono Coordinator for the firm and has served as pro bono co-counsel to a young El Salvadoran seeking asylum to escape gang violence, and a sex-trafficking victim, among others. She has been recognized in Chambers USA 2019. Since 2009, she has been recognized by “New York Super Lawyers” in the field of white-collar criminal defense. Since 2011, Ms. McCarthy has been listed in Best Lawyers in America. She is AV Rated in Martindale-Hubbell.

Ms. McCarthy also conducts sensitive internal investigations for corporate and institutional clients either facing potential criminal charges or whose officers or employees have engaged in misconduct. She has represented individuals who have been implicated, but not charged, in connection with recent major public corruption cases.

Ms. McCarthy assists clients in voluntarily disclosing off-shore assets and has successfully represented numerous clients in connection with both IRS and NYS tax audits involving sensitive matters, including undisclosed income and off-shore assets.

In 2013, Ms. McCarthy successfully represented Denis Field, the former CEO of BDO Seidman, in a major tax shelter trial in the Southern District of New York. After he had initially been convicted on all counts, Ms. McCarthy obtained Mr. Field’s acquittal on all counts in a re-trial, in a case described by the government as the largest criminal tax fraud in history.

Ms. McCarthy also has an extensive background in public service. From 1994 to 2006, Ms. McCarthy served as an Assistant United States Attorney in the Southern District of New York, where she served as lead counsel and supervisor of dozens of federal criminal jury trials and argued numerous appeals before the Second Circuit Court of Appeals. While in the U.S. Attorney’s Office, Ms. McCarthy served as Chief of the Violent Crimes Unit and Deputy Chief of the Criminal Division and served in the Public Corruption Unit. Ms. McCarthy was the recipient of the Director’s Award for Superior Performance as an Assistant United States Attorney in both 1996 and 1999. In 2011, she was appointed by the New York City Police Commissioner to the Crime Reporting Review Committee, whose report was issued in April 2013. From May 2008 to March 2009, she served as Special Counsel to the New York State Attorney General in an investigation into whether there had been political interference with the New York State Police.

Additionally, Ms. McCarthy was appointed by the United States District Court for the Southern District of New York in November 2020 as the first Independent Hearing Officer for the District Council of New York City and Vicinity of the United Brotherhood of Carpenters and Joiners of America. In March of 2013, Ms. McCarthy was appointed by the United States District Court for the Southern District of New York to the panel of attorneys assigned to advise and assist the Grievance Committee of the United States District Court for the Southern District of New York.
Prior to her service in the U.S. Attorney’s Office, Ms. McCarthy was an Associate at Lankler Siffert & Wohl and served as a Law Clerk to Judge John F. Keenan, United States District Judge for the Southern District of New York.

Ms. McCarthy is actively involved in various professional associations. She is a past President, and first woman to serve in that capacity, of the Fordham Law Alumni Association, the Chair of the Federal

Criminal Procedure Committee of the American College of Trial Lawyers, and a member of its Downstate New York Committee, and a member of the New York Council of Defense Lawyers. For over ten years, until September 2019, she was a member of the First Department’s Committee on Character and Fitness. From 2017-2018, she served as Vice President of the Association of the Bar of the City of New York, and from 2012-2015, she was Chair of the City Bar’s Criminal Law Committee. She is currently a member of the City Bar’s Judiciary Committee.

Ms. McCarthy is a 1989 graduate of Fordham Law School, where she served as an Articles Editor on the Fordham Law Review. She received a B.A. in 1985 from Colgate University.


Barbara Kaplan, Esq._Greenberg Traurig, New York, NY_myLawCLEBarbara Kaplan, Esq., | Greenberg Traurig, New York, NY

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

Sarah V. Spodick, Esq_Director, Low Income Taxpayer Clinic, Quinnipiac Law School_myLawCLESarah V. Spodick, Esq | Director, Low Income Taxpayer Clinic, Quinnipiac Law School



Jeffrey Sklarz, Esq._Green & Sklarz LLC, New Haven, CT_myLawCLEJeffrey Sklarz, Esq., | Green & Sklarz LLC, New Haven, CT

Jeff’s practice is focused on representing businesses and individuals with complex financial litigation needs including: bankruptcy/bankruptcy litigation, creditor/debtor litigation, tax litigation, and commercial litigation. He regularly tries cases and appeals before Connecticut’s state and federal courts. Jeff has particular experience regarding the interplay between bankruptcy and tax law.

Jeff was included in the 2021 Edition of The Best Lawyers in America© for Bankruptcy and Creditor Debtor Rights / Insolvency and Reorganization Law. He is a Fellow of the American College of Tax Counsel (ACTC). Jeff is a 2005 recipient of the Connecticut Law Tribune’s New Leaders of the Law Award (Overall Achievement, Fairfield County) and has been listed by New England Super Lawyer® as a Super Lawyer (Business Litigation) since 2010 (Rising Star 2010-2013) and was named a Fellow of the American Bar Association, Business Law Section (2011 – 2013).

Jeff received his B.A. in government from Colby College, his J.D. from the University of Connecticut, School of Law, and his LL.M. (Taxation) from Boston University, Graduate Tax Program.
Jeff holds (and has held) many positions with local and national bar organizations and is a frequent writer and lecturer on topics involving bankruptcy, tax litigation and commercial litigation. Current positions include: Chair of the Bankruptcy Study and Reform Committee of the American Bar Association, Business Law Section, and Program Director for the American Bar Association, Business Law Section, Business Bankruptcy Committee. Jeff is also currently President of the New Haven Jewish Community Center.
Jeff is frequent lecturer and writer on topics involving bankruptcy and tax. He is also the co-founder of the New England IRS Representation Conference.


Walter Pagano, CPA, CFE._Eisner Amper, New York, NY_myLawCLEWalter Pagano, CPA, CFE, | Eisner Amper, New York, NY

Walter Pagano is a Tax Partner and Tax Controversy Practice Leader. He has 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.


Jay Nanavati, Esq._Kostelanetz & Fink, LLP, Washington, DC_myLawCLEJay Nanavati, Esq., | Kostelanetz & Fink, LLP, Washington, DC

Jay R. Nanavati is an accomplished litigator, a former federal tax prosecutor, and a founding partner of Kostelanetz & Fink’s Washington, D.C., office. He has developed an enviable record of success in persuading the government to terminate investigations of his clients and in defeating the government in court.

Mr. Nanavati maintains a nationwide practice, focusing on white-collar criminal defense with an emphasis on tax-related matters. He 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 spent more than a decade as both a federal and a state prosecutor. He supervised more than 30 federal tax prosecutors and oversaw criminal tax enforcement for a region covering 22 states. He is a veteran trial lawyer, having conducted dozens of jury trials and hundreds of bench trials.

Mr. Nanavati is a Fellow of the American College of Tax Counsel, 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.


Zhanna A. Ziering, Esq._Caplin Drysdale, New York, NY_myLawCLEZhanna A. Ziering, Esq., | Caplin Drysdale, New York, NY

Zhanna A. Ziering is a Member in Caplin & Drysdale’s New York office. She offers guidance to individual and corporate clients who require sophisticated tax advice concerning their domestic tax issues, offshore assets, and U.S. reporting requirements.

Clients rely on Ms. Ziering’s deep knowledge of tax controversies and tax litigation, as well as her experience with related civil, criminal, and regulatory proceedings. Ms. Ziering represents both individuals and corporations before the U.S. Tax Court, federal and state courts, and administrative agencies, including the Internal Revenue Service, the Department of Justice, and other federal and state government regulators. Illustrations of Ms. Ziering’s services include:
•  advising clients on sensitive civil tax examinations by the IRS where fraud or substantial penalty issues may arise.
•  counseling advisors and other professionals on tax matters arising from investigations with U.S. regulators; and
•  defending clients in U.S. and state residency audits.
Ms. Ziering also serves as trusted counsel for clients facing offshore voluntary disclosure requirements on the federal and state levels. She advises clients on their U.S. tax reporting obligations relating to offshore assets and interests and assists in responding to audits and inquiries from the IRS and other government agencies. Representative examples of Ms. Ziering’s legal services include:
•  advising U.S. citizens living or working abroad, foreign nationals residing and working in the U.S., and foreign entities doing business in the U.S. about coming into tax compliance concerning their foreign accounts and
•  representing clients in civil tax dispute with New York and New Jersey.
Eric L. Green, Esq._Green & Sklarz LLC, New Haven, CT_myLawCLEEric L. Green, Esq., | Green & Sklarz LLC, New Haven, CT

The focus of Attorney Eric L. Green’s practice is taxpayer representation before the IRS, Department of Justice Tax Division, and state departments of revenue. He is a frequent lecturer on tax topics, including estate planning, and handling tax audits and tax controversies. Eric runs a weekly podcast found in ITunes called Tax Rep Network and is the author of The Accountant’s Guide to IRS Collection and The Accountant’s Guide to Resolving Tax Debts: Offers-in-Compromise, Installment Agreements & Uncollectable Status. Eric is the creator, author, and lecturer for the National Association of Tax Professionals Program in IRS Representation, which trains other professionals to handle IRS matters on behalf of clients. Mr. Green is a columnist for Forbes and CCH’s Journal of Tax Practice & Procedure.

Eric developed a national reputation by building a remarkable record of negotiating favorable settlements in thousands of civil cases against government agencies and has also been able to convince government agents and attorneys to forgo criminal charges and civilly resolve many cases.

Attorney Green has served as adjunct faculty at the University of Connecticut School of Law where he taught law students to handle taxpayer representation matters in the low-income taxpayer clinic. Prior to practicing law, Eric served as a senior tax consultant for national and international accounting firms, including KPMG and Deloitte & Touche.

Attorney Green’s commitment to professional excellence is demonstrated by his involvement in numerous professional organizations. He is a past Chair of the American Bar Association’s Closely Held Businesses Committee and has served as the chairman of the subcommittees on Business Succession Planning and Estate Planning. Attorney Green is a past Chair of the Connecticut Bar Association’s Tax Section and is a Member of its Estate & Probate Section.

Eric is a Fellow of the American College of Tax Counsel, an organization in which membership is an honor reserved for those at the top of their chosen profession. The College’s members, called “Fellows,” are recognized for their extraordinary accomplishments and professional achievements and for their dedication to improving the practice of tax law. Fellows must be nominated by their peers for this honor. Self-nomination is not permitted. Each nominee must satisfy the established criteria and pass a rigorous screening process before he or she becomes a Fellow.

Attorney Green is admitted to practice in New York, Connecticut and Massachusetts and is a member of the United States Tax Court Bar. Attorney Green is also a member of the Connecticut and Massachusetts Bar Associations, as well as the American Bar Association. Attorney Green received his Bachelor of Business Administration degree in Accounting with a minor in International Business from Hofstra University and is an honors graduate from New England School of Law. He earned a Master of Laws in Taxation from Boston University School of Law.


Sarah Paul, Esq._Eversheds Sutherland, New York, NY_myLawCLESarah Paul, Esq., | Eversheds Sutherland, New York, NY

Sarah Paul’s practice spans all areas of white-collar defense, with a particular focus on government, internal, and cross-border investigations, tax controversy, and cybersecurity and privacy law. She has extensive experience litigating complex criminal and civil cases.

Sarah joined Eversheds Sutherland from the United States Attorney’s Office for the Southern District of New York, where she served for over nine years as an Assistant United States Attorney in the Criminal Division. As a member of the Complex Frauds and Cybercrime Unit for nearly six years, she worked on sophisticated white-collar cases involving the investigation and prosecution of institutions and individuals for a variety of financial crimes, including Foreign Corrupt Practices Act violations, wire fraud, bank fraud, cybercrime, international money laundering, sanctions violations, securities fraud, health care fraud, and Bank Secrecy Act violations. She also served in the Money Laundering and Asset Forfeiture Unit, where she litigated substantial asset forfeiture matters, including significant art fraud cases. In 2019, Sarah was recognized by the Women in Federal Law Enforcement Foundation, which selected her from a nationwide pool of female federal prosecutors to receive the Top Prosecutor Award.

During her time as federal prosecutor, Sarah led numerous high-profile cross-border investigations, including an investigation resulting in the first US indictment in connection with the Panama Papers leak, an investigation resulting in a $547 million resolution with a Swiss bank and the guilty pleas of two Swiss bankers, and an investigation resulting in the guilty pleas of Cayman Islands investment brokerage and trust companies. Sarah also conducted fourteen federal jury trials and briefed and argued multiple appeals before the US Court of Appeals for the Second Circuit.

In 2016, she became the Tax Coordinator for the Criminal Division. During her two-and-a-half-year tenure as the Tax Coordinator, she supervised all criminal tax matters in the Southern District of New York, including hundreds of investigations and dozens of publicly charged cases, and she worked extensively with the Internal Revenue Service and the Tax Division of the Department of Justice.

Prior to her time as an Assistant United States Attorney, Sarah was a defense attorney for two prominent New York law firms, where she advised clients on anticipating, managing and mitigating legal and regulatory risks related to government enforcement and represented clients in all phases of criminal and civil litigation. She also worked as a federal law clerk for the Honorable Berle Schiller in the United States District Court for the Eastern District of Pennsylvania.


John D. (Don) Fort_Kostelanetz & Fink, LLP, Washington, DC_myLawCLEJohn D. (Don) Fort, | Kostelanetz & Fink, LLP, Washington, DC (former Chief of the Internal Revenue Service’s Criminal Investigation (CI) Division)

John D. (Don) Fort is the Director of Investigations at Kostelanetz & Fink, 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, Mr. Fort has deep expertise in financial crimes, and has developed an extensive network of connections both within the government and in private industry.

At K&F, he now 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. Mr. Fort also is involved in conducting internal investigations and advising clients on compliance regimes. He is available as an expert witness and for voluntary or court-mandated monitorships.

Mr. Fort’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 Chief of IRS-CI from 2017 to 2020, Mr. Fort 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. Mr. Fort modernized IRS-CI by developing cutting-edge, data-centric methods of detecting criminal non-compliance through algorithms and other models. Mr. Fort also significantly expanded IRS-CI’s capabilities in cyber-crime and cryptocurrency investigations and expanded the agency’s international presence and footprint. Mr. Fort led IRS-CI in identifying and investigating over $11.5 billion in tax loss and $14.8 billion in other criminal proceeds.

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.

Mr. Fort began his IRS career in 1991 as a Special Agent in Baltimore, Maryland, and later served as Supervisory Special Agent in Orlando, Florida; Senior Analyst and Acting Director, Office of Special Investigative Techniques; Assistant Special Agent in Charge of the Baltimore and Washington, D.C. Field Offices; Special Agent in Charge of the Philadelphia, Pennsylvania, Field Office; and Deputy Director of Strategy, IRS-CI Headquarters.

Mr. Fort entered the Senior Executive Service in January 2011, when he was appointed to serve as a Director of Field Operations–the position he held until his appointment as Deputy Chief, IRS-CI. In 2020, Mr. Fort was the recipient of the ACAMS Public-Private Partnership Award.

Mr. Fort is an accomplished public speaker and serves as an expert in law enforcement, leadership, financial crimes, and enhancing public-private partnerships. As Chief of IRS-CI, Mr. Fort was also regularly called upon to deliver media briefings and give interviews on important matters before the IRS. Mr. Fort has extensive experience in briefing high-level government officials, has testified before Congress and has provided numerous briefings to congressional staff.

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


Bryan Skarlatos, Esq._Kostelanetz & Fink, LLP, New York, NY_myLawCLEBryan Skarlatos, Esq. | Kostelanetz & Fink, LLP, New York, NY

For more than thirty years, Bryan C. Skarlatos has represented corporations and individuals in sensitive matters, many of which involve negotiation or litigation with government agencies. He has significant experience in federal and state tax audits, appeals and litigation, criminal tax investigations and white-collar criminal prosecutions. Mr. Skarlatos also has an active practice providing tax and estate planning advice.
Mr. Skarlatos is an internationally recognized expert on reporting foreign assets to the Internal Revenue Service and has handled hundreds of voluntary disclosures, civil audits and criminal investigations involving alleged failure to report foreign assets. He also counsels corporations and individuals from around the world on how to come into compliance with U.S. tax law.
Mr. Skarlatos has been an adjunct professor at New York University School of Law for nearly twenty years where he teaches a class on Tax Penalties, Prosecutions and Procedures. He has developed an expertise in handling high stakes tax cases that could involve penalties or other sensitive issues. He is often retained by corporate taxpayers to evaluate the strength of tax positions for tax and financial reporting purpose and to advise on potential remedial actions, including corporate voluntary disclosures.
Mr. Skarlatos is also very experienced in tax whistleblower matters and represents both taxpayers accused of wrongdoing by whistleblowers as well as whistleblowers themselves in claims before federal and state tax authorities. Mr. Skarlatos testified before the Internal Revenue Service regarding the IRS whistleblower law and was retained by Senator Charles Grassley, the drafter of the IRS whistleblower law, to write an amicus brief on behalf of the Senator in the D.C. Circuit Court of Appeals.
Mr. Skarlatos is often retained as an expert in tax reporting standards and tax penalties by professionals, firms, and taxpayers accused of violating those standards. Mr. Skarlatos has been hired as an expert on criminal tax issues by a state prosecutor’s office and a foreign government. He has also testified before the U.S. House of Representatives Ways and Means Committee as an expert on tax penalties. Mr. Skarlatos has been recognized by Super Lawyers as one of the Top 100 Lawyers in New York and in Best Lawyers in America where he was named “Lawyer of the Year” (Tax Litigation, New York) in 2014 and 2017. He is also ranked Band One of Chambers USA: Americas Leading Lawyers for Business, which describes him as having a “smart reassuring presence with insight into the government…extremely knowledgeable and very well connected to the various tax authorities…Clients applaud him as being exceptionally brilliant at coming up with great outcomes.”

Sara G. Neill, Esq._Capes Sokol, St. Louis, MO_myLawCLESara G. Neill, Esq., | Capes Sokol, St. Louis, MO

The Chair of Capes Sokol’s Tax Controversy and Litigation Practice Group, Sara Neill represents clients in civil and criminal tax disputes and litigation involving the Internal Revenue Service, Department of Justice and Missouri and Illinois Departments of Revenue. Sara was recognized as the St. Louis “Litigation and Controversy—Tax Lawyer of the Year” by Best Lawyers in both 2015 and 2018.

Sara handles federal and state tax audits and administrative appeals, as well as litigation before the U.S. Tax and District Courts. She frequently advises both individuals and businesses with sensitive tax problems, such as those who have failed to file returns, underreported their income, neglected to remit trust fund taxes to the Internal Revenue Service, pay significant amounts of tax due, or disclose foreign assets and accounts. She also regularly represents clients in criminal tax investigations and litigation. Sara has defended several lawyers and accountants in IRS preparer/promoter investigations and appeals, as well as criminal tax cases. She frequently advises tax professionals with respect to matters involving Circular 230 and the IRS Office of Professional Responsibility, as well as in ethics and other disciplinary matters involving their professional licensing boards.

In addition to tax matters, Sara represents clients in other white-collar criminal matters involving allegations of financial fraud, including in the healthcare and securities areas.


Damon Rowe, Director, Fraud Enforcement Office, Internal Revenue Service, Washington, DC_myLawCLEDamon Rowe, Director, Fraud Enforcement Office, Internal Revenue Service, Washington, DC



Caroline D. Ciraolo, Esq._Kostelanetz & Fink LLP, Washington, DC_myLawCLECaroline D. Ciraolo, Esq. | Kostelanetz & Fink LLP, Washington, DC

Caroline D. Ciraolo, former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division, is a partner with Kostelanetz & Fink and a founder of its Washington, D.C. office. Her practice focuses on complex and sophisticated civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation in federal and state courts and administrative tax tribunals, providing related tax advice, conducting internal investigations, consideration of domestic and foreign compliance options including voluntary disclosures, and representing individuals and institutions in criminal tax investigations and prosecutions.

During her tenure with the Justice Department, Caroline was actively involved in all aspects of Tax Division operations and responsible for approximately 500 employees, including more than 360 attorneys in 14 civil, criminal and appellate sections. Under her leadership, the Division reached agreements with 80 Swiss financial institutions that admitted to facilitating tax evasion and the avoidance of reporting requirements by U.S. account holders, and imposed and collected more than $1.36 billion in penalties, increased civil and criminal enforcement with respect to offshore tax evasion, employment tax violations, and traditional tax offenses, assisted the IRS through summons enforcement proceedings, and engaged in affirmative and defensive litigation involving abusive tax shelters and schemes, refund claims, and challenges to statutes and regulations.

Prior to joining the Department, Caroline was Chair of the Tax Controversy and Litigation practice group of a regional firm in Baltimore, Maryland, where she represented individuals and businesses in all phases of state and federal civil tax controversies and criminal tax investigations and prosecutions. She has appeared before the IRS, the Comptroller of Maryland and the D.C. Office of Tax and Revenue, the Maryland Tax Court, the U.S. Tax Court, U.S. District Courts, the Maryland circuit and appellate courts and the U.S. Court of Appeals for the Fourth and Federal Circuits.

Caroline is a Fellow and Officer of the American College of Tax Counsel and Chair of the Civil and Criminal Tax Penalties Committee of the American Bar Association’s Section of Taxation. Caroline has also served as an instructor with the IRS Military Volunteer Income Tax Assistance program at Ft. George G.Meade in Maryland.

She has been recognized by Chambers (Tax Fraud (Nationwide), Tax (DC)), Benchmark, Best Lawyers in America (Litigation and Controversy – Tax, Tax Law), Super Lawyers (Top 10 Attorneys in Maryland, Maryland cover story in 2013, DC), Euromoney Legal Media Group’s Americas Women in Business Law Awards (Best in Tax Dispute Resolution) (2014), and The Daily Record’s Top 100 Women Circle of Excellence. Caroline is a recipient of the ABA Section of Taxation’s Janet Spragens Pro Bono Award, and in January 2017, she was recognized by IRS Chief Counsel William Wilkins with the Chief Counsel Award, the highest honor that can be conferred by that office.

Caroline is an Adjunct Professor at the Georgetown University Law Center (International Tax Controversies, Criminal Tax Law and Procedure) and University of Baltimore School of Law Graduate Tax Program (Investigation, Prosecution and Defense of Tax Crimes).

myLawCLE Blue_myLawCLEAnastasia King, Asst. United States Attorney, New Haven, CT



myLawCLE Blue_myLawCLEJeffrey Miller, Supervisory Special Agent, IRS Criminal Investigation, White Plains, NY



Sareena Sawhney, MBA, CFE,_Withum, Smith & Brown, PC, New York, NY_myLawCLESareena Sawhney, MBA, CFE, | Withum, Smith & Brown, PC, New York, NY

Sareena Sawhney is based out of New York City and is a Principal in Withum’s Forensic and Valuation Services group. She specializes in complex fraud investigations, forensic accounting, and white-collar defense matters as well as services related to commercial litigation and professional liability matters. Her experience includes conducting fraud and white-collar investigations, calculating commercial damages, shareholder disputes and bankruptcy fraud analyses for mid-size to Fortune 500 companies. She has also assisted counsel and insurance companies in refuting claims related to E&O and D&O liability matters. Sareena has served as testifying expert witness and worked with counsel to develop case studies, depositions and reports and exhibits for trial. Throughout her career, she has lectured and published articles on various forensic, white-collar and litigation support topics.

Sareena was awarded as one of the most Notable Women in Accounting & Consulting by Crains Magazine in 2020 and 2019. Sareena is a Certified Anti-Money Laundering Specialist (CAMS), Certified Fraud Examiner (CFE) and Master Analyst in Financial Forensics (MAFF). She is also a member of the National Association of Certified Valuation Analysts (NACVA), Association of Anti-Money Laundering Specialists (ACAMS), Association of Certified Fraud Examiners (ACFE) and Financial Women’s Association.

Sareena earned her BA in Economics at Stony Brook University and her Masters in Business Administration in Finance at Loyola University New Orleans.


I. Registration & Breakfast | 8:00 – 8:30 am
II. Welcome & Housekeeping Announcements | 8:30 – 8:45 am
III. What’s New in Criminal Tax | 8:45 – 9:45 am
IV. Parallel Civil & Criminal Investigations | 9:45 – 10:45 am

V. Break | 10:45 – 11:00 am

VI. PPP Loan Fraud | 11:00 – 12:00 pm

VII. Lunch | 12:00 – 12:30 pm

VIII. The IRS’s Use of Artificial Intelligence in Criminal Tax Cases | 12:30 – 1:30 pm
IX. Non-Filers | 1:30 – 2:30 pm

X. Break | 2:30 – 2:45 pm

XI. The Criminal Investigation Part 1: Inside the Defense Room | 2:45 – 4:00 pm
XII. The Criminal Investigation Part 2: Meeting with the Government | 4:00 – 5:00 pm