16th Annual NYU Tax Controversy Forum
Register Today!
on June 27 and 28, 2024!
At the Westin New York at Times Square
Overview
Kostelanetz LLP is pleased to sponsor the 2024 NYU Tax Controversy Forum, which will be held on Thursday and Friday, June 27 and 28, 2024, at the Westin New York at Times Square. We will have more information about registration and the agenda as it approaches, but our lineup of speakers will be as robust and interesting as it has been for the past 16 years. As in past years, we expect an exciting array of senior government speakers and interactive presentations delivered by expert practitioners who cover a broad range of issues regarding tax audits and tax litigation at all levels. This is the one event you can’t miss!
2024 Speakers
Lia Colbert, Commissioner, IRS Small Business/Self Employed Division
Erin M. Collins, Esq., National Taxpayer Advocate, IRS
Sharyn M. Fisk, Esq., Director, Office of Professional Responsibility, IRS
John W. Hinman, Director, Whistleblower Office, IRS
David A. Hubert, Esq., Principal Deputy Assistant Attorney General, Tax Division, US Department of Justice
Guy Ficco, Chief, Criminal Investigation Division, IRS
Casey A. Lothamer, Esq., Area Counsel, Mid-Atlantic Region, Tax Exempt Government Entities, IRS
Heather Maloy, Esq., Chief Taxpayer Compliance Officer, IRS
Mary Beth Murphy, Director of Collections, North Atlantic Territory, Small Business/Self Employed Division, IRS
Mark Nyman, Director, Corporate Issues/Credits, IRS
Holly O. Paz, Esq., Commissioner, Large Business and International Division, IRS
Marjorie A. Rollison, Esq., Chief Counsel, Office of Chief Counsel, IRS
Trisha M. Turner, Senior Advisor, Office of the Digital Assets Initiative, IRS
2024 Tax Controversy
Forum Co-Chairs
Caroline D. Ciraolo, Esq.
Partner, Kostelanetz LLP, Washington, DC
Miri Forster, Esq.
Partner and National Tax Controversy Leader, EisnerAmper, New York, NY
About the Forum
For more than 16 years, Kostelanetz LLP and the NYU School of Professional Studies have brought together government representatives and expert private practitioners to share their perspectives on a variety of topics involving federal tax audits, appeals, and litigation for the annual Tax Controversy Forum. The forum covers a wide range of controversy work, from procedural seminars to substantive programs, international issues, ethical problems, current enforcement initiatives, sensitive audits, and civil and criminal tax penalties.
We’ll be gathering in person at the Westin New York at Times Square. The hotel is located in the heart of New York City, just steps from Times Square and near major Broadway show venues, flagship retail shopping, and fine dining restaurants. We invite you to come and experience the city, all while renewing friendships, networking, and hearing from some of the brightest legal minds in the tax bar.
NYU TAX CONTROVERSY FORUM 2024
– IN-PERSON and ONLINE PROGRAM
Thursday and Friday, June 27 and 28, 2024
– IN-PERSON and ONLINE PROGRAM
Thursday and Friday, June 27 and 28, 2024
Thursday, June 27th
8:00 am – 5:30 pm
8:00 am
REGISTRATION AND CONTINENTAL BREAKFAST
8:30 am
WELCOME
Kathleen Costello, CMP, Assistant Director, NYU School of Professional Studies, New York, NY
Caroline D. Ciraolo, Esq., Partner, Kostelanetz, Washington, DC
Miri Forster, Esq., Partner and National Tax Controversy Leader, EisnerAmper, New York, NY
TAX COMPLIANCE AND ENFORCEMENT UPDATE: PART I
Voluntary compliance and enforcement of the tax law are at the heart of our tax system. Over the past several years, the IRS and DOJ have been challenged to come up with new and more efficient ways to ensure that all taxpayers pay the correct amount of tax. These panels provide an update on new developments and priorities across various divisions of the government.
8:45 am
WHAT’S NEXT FOR THE IRS? AN UPDATE FROM SENIOR IRS EXECUTIVES
There is a lot going on at the IRS! The IRS announced a new leadership structure to align to its new priorities, funding from the IRS Inflation Reduction Act is being used to support better customer service, increased enforcement, and modernization, and digital transformation is on the horizon. Hear directly from senior IRS executives as they discuss the plans for the future, hiring trends, the compliance and enforcement focus, and other critical areas.
Moderator: Sharon Katz-Pearlman, Esq., Shareholder, Greenberg Traurig, New York, NY
Lia Colbert, Commissioner, Small Business/Self-Employed Division, Internal Revenue Service, Washington, DC
Heather Maloy, Esq., Chief Taxpayer Compliance Officer, Internal Revenue Service, Washington, DC
Holly O. Paz, Esq., Commissioner, Large Business and International Division, Internal Revenue Service, Washington, DC
9:45 am
CRIMINAL TAX ENFORCEMENT UPDATE
CRIMINAL TAX ENFORCEMENT UPDATE
With the increase in the IRS enforcement budget coupled with the recent focus on fraud enforcement, tax professionals are preparing for a rise in criminal tax investigations and prosecutions. This panel features Guy Ficco, new Chief of IRS Criminal Investigation, and top criminal tax defense experts on the latest trends and developments in criminal tax. Topics include enforcement priorities, technological innovations and data analytics, public-private partnerships, IRS funding and developments in cryptocurrency enforcement. Practitioners share practical tips on working with IRS-CI and tips on how to navigate the sensitivities of an IRS criminal investigation.
Moderator: Don Fort, CPA, Director of Investigations, Kostelanetz, Washington, DC
Guy Ficco, Chief, Criminal Investigation Division, Internal Revenue Service, Washington, DC
Caryn Finley, Esq., Assistant US Attorney, US Attorney’s Office, Western District of North Carolina, Charlotte, NC
Jason B. Freeman, Esq., Managing Member, Freeman Law PLLC, Dallas, TX
Jeremy H. Temkin, Esq., Principal, Morvillo Abramowitz Grand Iason & Anello PC, New York, NY
10:45 am
REFRESHMENT BREAK
10:55 am
US DEPARTMENT OF JUSTICE TAX DIVISION UPDATE
Moderator: Michael J. Desmond, Esq., Partner, Gibson, Dunn & Crutcher, Los Angeles, CA and Washington, DC
David A. Hubbert, Esq., Principal Deputy Assistant Attorney General, Tax Division, US Department of Justice, Washington, DC
11:25 am
DIVERSITY, INCLUSION AND ELIMINATION OF BIAS CREDIT: ELIMINATING BIAS IN REPRESENTING THE IMMIGRANT WORKER AND THEIR EMPLOYER
Immigrant workers support America’s business community. Rather than taking jobs away from American workers, studies show that immigrant workers create new jobs by forming new businesses, spending income on American goods and services, and paying more than $90 billion in taxes each year. Despite these contributions, immigrant workers and their American employers face challenges and implicit bias in their efforts to comply with US tax laws. This panel explains how immigrant workers fit within our tax framework, common issues that arise, the existence and consequences of implicit bias, and paths to compliance for both the worker and the employer.
Moderator: Nina E. Olson, Esq., Executive Director, Center for Taxpayer Rights, Washington, DC
Frank Agostino, Esq., Founder & President, Agostino & Associates, PC, Hackensack, NJ
Jacqueline Laínez Flanagan, Esq., Deputy Director, Center for Taxpayer Rights, Washington, DC
Carlos F. Ortiz, Esq., Partner, BakerHostetler, New York, NY
Anna Tavis, Esq., Staff Attorney, Brooklyn Legal Services, Brooklyn, NY
12:15 - 1 pm (LUNCHEON)
Buffet lunch served
1 - 1:50 pm (BREAK OUT SESSIONS)
TRACK I
AUDITS OF EXEMPT ORGS AND PRIVATE FOUNDATIONS: TAX EXEMPT DOES NOT MEAN NO ENFORCEMENT!
The IRS is expanding its pursuit of high net-worth taxpayers with a renewed focus on the structures and transactions used to avoid and evade US tax obligations. To this end, the IRS Exempt Organizations Examinations program seeks to promote voluntary compliance by analyzing the operational and financial activities of exempt organizations and determining whether the organizations accurately filed required returns and reports. This panel of expert practitioners explores the complex tax and regulatory issues that apply to exempt organizations, explains common audit issues and the risks of noncompliance including substantial excise tax liabilities, and offers best practices in bringing exempt organizations into compliance.
Moderator: John Colvin, Esq., Partner, Colvin + Hallet, Seattle, WA
Meghan R. Biss, Esq., Partner, Caplin & Drysdale, Chartered, Washington, DC
Casey A. Lothamer, Esq., Area Counsel, Mid-Atlantic Region, Tax Exempt Government Entities, Internal Revenue Service, Washington, DC
Josh O. Ungerman, Esq., CPA, Partner, Meadows, Collier, Reed, Cousins, Crouch & Ungerman, Dallas, TX
TRACK II
THINK GLOBALLY: INTERNATIONAL TAX ENFORCEMENT AND DISPUTES
Understanding international tax reporting and filing obligations is vital to businesses operating in a global environment. With the push to close Tax Gaps and crack down on aggressive tax avoidance, the increase in collaboration among treaty partners, and the surge in tax examinations and investigations, it is more important than ever to stay up to date on the latest developments in international tax enforcement and disputes. This panel of international tax experts addresses recent developments in cross-border tax matters including transfer pricing, double taxation, exchange of information, international audit tools and the like.
Moderator: Heather Fincher, Esq., Associate, Kostelanetz, Washington, DC
David Farhat, Esq., Partner, Skadden Arps Slate Meagher & Flom, Washington, DC
Joshua Odintz, Esq., Partner, Holland & Knight, Washington, DC
Christopher Slade, Esq., Partner, Aird & Berlis, Toronto, Canada
1:50 pm (BREAK)
2:10 - 3 pm (BREAK OUT SESSIONS)
TRACK I
THE ROLE OF THE FORENSIC ACCOUNTANT
Forensic accountants use specialized techniques to uncover and explain financial and accounting anomalies and improper conduct. They are retained as consultants and testifying experts in a broad range of civil and criminal tax cases, serving as essential components of a legal team’s resolution strategy. This panel explores the role of the forensic accountant and how they can best work with tax practitioners in defending their client in a tax controversy.
Moderator: Walter Pagano, CPA, CFE, CFF, Partner, EisnerAmper, New York, NY
Kevin Hanff, Partner, Integritas3, Pensacola, FL
Susan Markel, CPA, Partner and Managing Director, AlixPartners, Washington, DC
Manny Muriel, MBA, EA, Partner, Bishop Muriel & Weirauch, East Islip, NY
TRACK II
THE ADMINISTRATIVE PROCEDURE ACT v. THE IRS: WHICH REGULATIONS, RULES, AND NOTICES WILL SURVIVE?
Ever since the Supreme Court rejected that Treasury Regulations are reviewed differently in Mayo Foundation v. United States, 562 U.S. 44 (2011), challenges to tax regulations and IRS notices have proliferated. Courts have now developed a full body of jurisprudence regarding application of the Administrative Procedure Act (“APA”) to tax cases. Have we reached the end of “tax exceptionalism”? How will the APA apply to the blizzard of new regulations under the TCJA and old regulations promulgated in a pre-Mayo world? This panel addresses these questions and explores the current state of the law on the APA as it applies to tax including the Loper Bright Enterprises, Relentless Inc., and Corner Post Supreme Court cases.
Moderator: Andrew Weiner, Esq., Counsel, Kostelanetz, Washington, DC
David W. Foster, Esq., Partner, Kirkland & Ellis, Washington, DC
Katherine Jordan, Esq., Director of Tax Controversy, GBX Group, Cleveland, OH
Michelle Abroms Levin, Esq., Shareholder, Dentons Sirote, Huntsville, AL
3:00 pm (REFRESHMENT BREAK)
3:20–4:10 pm (BREAK OUT SESSIONS)
TRACK I
CRIMINAL INVESTIGATIONS—PLANNING FOR THE WORST TO ACHIEVE THE BEST RESULT
At the outset of a federal criminal tax investigation, the primary objective of a subject or target is generally universal – avoiding criminal charges. Defense counsel must pursue this objective while planning for an eventual indictment and a strong defense at trial. This panel of criminal tax trial lawyers shares their experience in managing the substantive and procedural issues that arise in criminal tax investigations to best prepare for the prosecution their clients hope to avoid.
Moderator: Guinevere M. Moore, Esq., Managing Member, Moore Tax Law Group, Chicago, IL
Sara G. Neill, Esq., Founding Shareholder, Neill Schwerin Boxerman, PC, Clayton, MO
Jeffrey A. Neiman, Esq., Partner, Marcus Neiman Rashbaum & Pineiro, Fort Lauderdale, FL
Rod J. Rosenstein, Esq., Partner, King & Spalding, Washington, DC
TRACK II
YOUR CLIENT EARNS MORE THAN $400,000 – EFFECTIVELY MANAGING IRS EXAMINATIONS OF THE HIGH INCOME/HIGH NET WORTH TAXPAYER
Secretary Yellen and the IRS have made it clear that increased audits and additional resources will focus on US taxpayers with annual income of more than $400,000, targeting “high-end noncompliance” involving wealthy individuals, large corporations, complex pass-through entities, and exempt organizations. IRS Large Business & International, working with other IRS operating divisions, are investing resource in these efforts and announcing new compliance campaigns including but not limited to corporate jet deductions, art donations and sports industry losses. This panel of expert practitioners provides an overview of the IRS high-end enforcement efforts, issues being raised in related audits and investigations, and best practices in defending your clients.
Moderator: Emily P. Hughes, PC, Esq., Partner, Kirkland & Ellis, Washington, DC
Niles A. Elber, Esq., Member, Caplin & Drysdale, Chartered, Washington, DC
S. Starling Marshall, Esq., Partner, Crowell & Moring, New York, NY
Fran Obeid, Esq., Founder, MFO LAW, PC, New York, NY
4:10 pm (Break)
4:30 - 5:30 pm (BREAK OUT SESSIONS)
TRACK I
IRA CLEAN ENERGY CREDITS AND ANTICIPATED ENFORCEMENT
The EPA describes the Inflation Reduction Act of 2022 (“IRA”) as “the most significant climate legislation in US history, offering funding, programs, and incentives to accelerate the transition to a clean energy economy” and predicts that the Act will drive the deployment of new clean electricity resources. Under the IRA, certain businesses and tax-exempt entities may deduct a percentage of the cost of renewable energy systems from federal tax and, in some cases, directly monetize or transfer tax credits to unrelated parties. With these tax benefits will come increased enforcement to ensure that taxpayers are not abusing the system. This panel addresses the various clean energy credits under the IRA, the eligibility and filing requirements, current and forthcoming Treasury and IRS guidance, and what we can expect in future audits and investigations.
Moderator: Carina C. Federico, Esq., Partner, Crowell & Moring, Washington, DC
Shirley Chin, Esq., Head of Tax Insurance, WTW, San Francisco, CA
Ian M. Comisky, Esq., Partner, Fox Rothschild, Philadelphia, PA
Mark Nyman, Director, Corporate Issues/Credits, Internal Revenue Service, New York, NY
Philip J. Wilson, CPA, Office Managing Partner, Marcum, Costa Mesa, CA
TRACK II
CHALLENGING CIVIL PENALTIES-RECENT DEVELOPMENTS
The IRS has substantially increased the assertion and assessment of civil penalties, arguably to encourage compliance but often in cases where the punishment far exceeds the violation. While staggering penalties for filing late international information returns and Reports of Foreign Bank and Financial Accounts are often front-page news, taxpayers also are challenging erroneous refund penalties, Affordable Care Act and other domestic information reporting penalties, valuation penalties, and delinquency penalties. The IRS is even considering penalties under the economic substance doctrine. This panel explores recent civil penalty developments, available defenses, and best practices, and discusses recent decisions and pending cases including Lu v. Commissioner, Mukhi v. Commissioner, Groves v. Commissioner, Ueland v. United States, Farhy v. Commissioner, and more!
Moderator: Michel R. Stein, Esq., Principal, Hochman Salkin Toscher Perez, PC, Beverly Hills, CA
Byung Hyuk Min, Esq., Associate, Agostino & Associates, Hackensack, NJ
Daniel N. Price, Esq., Law Offices of Daniel N. Price, PLLC, San Antonio, TX
Zhanna A. Ziering, Esq., Member, Moore Tax Law Group, New York, NY
Lawrence A. Sannicandro, Esq. Partner, McCarter & English, Newark, NJ
5:30 pm (RECESS)
Friday, June 28th
8:00 am – 4:50 pm
8:00 am
REGISTRATION AND CONTINENTAL BREAKFAST
TAX COMPLIANCE AND ENFORCEMENT UPDATE: PART II
Voluntary compliance and enforcement of the tax law are at the heart of our tax system. Over the past several years, the IRS has been challenged to come up with new and more efficient ways to ensure that all taxpayers pay the correct amount of tax. These panels provide an update on new developments at the IRS and the United States Tax Court.
8:45 am
ETHICS CREDIT: HANDLING EMPLOYEE RETENTION CREDIT AUDITS AND INVESTIGATIONS—COLORING IN THE LINES
Claims for Employee Retention Credits (“ERCs”) have proliferated exponentially. To address questionable claims, the IRS recently announced a Voluntary Withdrawal and Voluntary Disclosure Program to give taxpayers with possibly ineligible claims an opportunity to come forward, cooperate with the IRS, and, in return, minimize their financial exposure including penalties. The IRS is also aggressively auditing ERC claims and pursuing penalties and criminal prosecutions for ERC related abusive schemes and fraud. This panel of experienced practitioners discusses the IRS’s targeted enforcement efforts, explains how to spot red flags indicating abuse of the ERC, describes the penalties that apply to taxpayers, promoters, and practitioners for erroneously claiming ERC credits, and addresses the filing of the corresponding wage reduction on an income tax return.
Moderator: Thomas A. Cullinan, Esq., Shareholder, Chamberlain, Hrdlicka, White, Williams & Aughtry, PC, Atlanta, GA
Sandra R. Brown, Esq., Principal, Hochman Salkin Toscher Perez PC, Beverly Hills, CA
Sharyn M. Fisk, Esq., Director, Office of Professional Responsibility, Internal Revenue Service, Washington, DC
Daniel Mayo, Esq., Partner, WithumSmith+Brown, PC, Red Bank, NJ
Eric Hylton, National Director, alliantGroup, Washington, DC
9:45 am
IRS WHISTLEBLOWER OFFICE UPDATE
With the enactment of Section 7623, claims for whistleblower awards have skyrocketed and the IRS Whistleblower Office has a full plate of work: processing new submissions; managing open claims and issuing awards. To ensure it is successfully meeting these challenges, the Whistleblower Office has embarked on an ambitious Whistleblower Program Improvement Plan. Key goals of the improvement plan include: increasing high-value claims coming in; improving the Whistleblower’s Office ability to identify such claims; and better tracking of such claims through improved systems – and efforts to pay awards sooner. This panel provides an update from the IRS Whistleblower Office on recent reform efforts, highlights issues the IRS is particularly interested in hearing more about from whistleblowers, what makes for a good whistleblower submission, as well as touches on recent court decisions addressing this important practice area.
Moderator: Dean Zerbe, Esq. Partner, Zerbe, Miller, Fingeret, Frank & Jadav, Houston, TX
John W. Hinman, Director, Whistleblower Office, Internal Revenue Service, Washington, DC
10:10 am
IIRS COLLECTION UPDATE
Issuance of IRS collection notices have resumed and IRS collection efforts from high income non-filers and those with outstanding tax debt have brought in millions of dollars since FY 2023. This panel provides an update from IRS Collection on recent collection efforts, availability of new collection tools and expectations for the future that impacts every tax practice.
Moderator: Beverly Winstead, Esq., Principal, Law Office of Beverly Winstead, Baltimore, MD
Mary Beth Murphy, Director of Collections, North Atlantic Territory, Small Business/Self-Employed Division, Internal Revenue Service, Washington, DC
10:35 am
TAXPAYER ADVOCATE UPDATE
Erin Collins became the National Taxpayer Advocate (“NTA”) on March 30, 2020, at the outset of the COVID-19 pandemic. With the IRS pushed to its breaking point, Collins and her team continued their dual focus on addressing systemic issues (of which there were many) and handling individual taxpayer cases (of which there were even more). Hear about the lessons learned over Collins’ past four years in the role and the NTA’s priorities and vision for the future of the newly funded IRS.
Moderator: Todd Welty, Esq., WELTY PC, partner, Kostelanetz LLP, Atlanta, GA
Erin M. Collins, Esq., National Taxpayer Advocate, Internal Revenue Service, Washington, DC
11:00 am (REFRESHMENT BREAK)
11:15 am
UPDATES FROM THE IRS OFFICE OF CHIEF COUNSEL AND US TAX COURT
The IRS Office of Chief Counsel and the US Tax Court both play important roles in the resolution of cases that have not been resolved at audit or in appeals. This panel provides insight into cases involving the Office of Chief Counsel and the US Tax Court, challenges presented by those cases, and how those challenges are being addressed.
Moderators: Jennifer Breen, Esq., Partner, Morgan Lewis & Bockius, Washington, DC; Diana L. Erbsen, Esq., Partner, DLA Piper, New York, NY
The Hon. Elizabeth A. Copeland, Judge, United States Tax Court, Washington, DC
Marjorie A. Rollison, Esq., Chief Counsel, Office of Chief Counsel, Internal Revenue Service, Washington, DC
12:15 - (LUNCH RECESS)
1:30–2:20 pm (BREAK OUT SESSIONS)
TRACK I
EMPLOYMENT TAXES—CIVIL AND CRIMINAL ENFORCEMENT
Employment taxes make up approximately 70% of all revenue collected by the IRS and employment tax non-compliance is a significant contributor to the annual Tax Gap. The IRS and Department of Justice continue to target this area with a variety of tools including audits, civil penalties, injunctions, and criminal investigations. This panel of experienced practitioners explores the government’s priorities in the employment tax space, the various enforcement efforts pursued, and strategies and best practices for navigating clients through these difficult waters.
Moderator: Christopher M. Ferguson, Esq., Partner, Kostelanetz, New York, NY
Megan E. Marlin, Esq., Principal, PwC, Washington, DC
Richard J. Sapinski, Esq., Partner, Sills Cummis & Gross PC, Newark, NJ
James A. Ulicny, Esq. Attorney, Office of Chief Counsel (Criminal Tax), Internal Revenue Service, New York, NY
TRACK II
SURVIVING AN AUDIT AND ADMINISTRATIVE APPEALS UNDER THE CENTRALIZED PARTNERSHIP AUDIT REGIME
The Bipartisan Budget Act (“BBA”) was signed into law November 2, 2015, replacing the audit and collection procedures for partnerships under the Tax Equity and Fiscal Responsibility Act of 1982 (“TEFRA”) for tax years beginning January 2018. BBA audits are on the rise, and revenue agents and tax professionals are working together to navigate these choppy waters. This panel explains the centralized partnership audit regime and recent partnership audit trends, notices to expect from the IRS, actions to take during the audit, methods to challenge proposed adjustments, and the impact on the individual partners.
Moderator: Miri Forster, Esq., Partner and National Tax Controversy Leader, EisnerAmper, New York, NY
Hans Famularo, Esq., Special Counsel, Office of Chief Counsel, Small Business/Self-Employed Division, Internal Revenue Service, Laguna Niguel, CA
Abbey Garber, Esq., Partner, Holland & Knight, Dallas, TX
Kelley C. Miller, Esq., Partner, Reed Smith, Washington, DC
2:20 pm (REFRESHMENT BREAK)
2:40 - 3:30 pm (BREAK OUT SESSIONS)
TRACK I
CORPORATE TRANSPARENCY ACT/NEW YORK LLC TRANSPARENCY ACT
The Corporate Transparency Act (CTA) creates new reporting requirements for companies created or registered to do business in the US. The CTA is effective January 1, 2024, and requires reporting companies to provide information on their company and its beneficial owners to the Financial Crimes Enforcement Network (FinCEN). Similarly, New York has passed its own NY LLC Transparency Act. This panel discusses who is subject to the reporting requirements, what information to report, the consequences for non-compliance, and how best to address recent cases (pending appeal) that have ruled the CTA is unconstitutional.
Moderator: Phillip Colasanto, Esq., Senior Associate, Withers Bergman LLP, New York, NY
Yvonne R. Cort, Esq., Partner, Capell Barnett Matalon & Schoenfeld, Syosset, NY
Jay R. Nanavati, Esq., Partner, Kostelanetz, Washington, DC
Melissa L. Wiley, Esq., Partner, Lowenstein Sandler, Washington, DC
TRACK II
CREATIVE COLLECTION ALTERNATIVES
Issuance of collection notices have resumed in full force and the IRS has increased its efforts to pursue high net worth taxpayers with outstanding tax debt. One of the most common questions raised by taxpayers faced with potential or assessed tax liabilities is: What are my options? A simple question that requires the tax professional to explain the numerous and often complex paths to resolving federal tax liabilities. While navigating the numerous options, taxpayers must address ever-increasing enforcement actions, including, but not limited to, the filing of Notices of Federal Tax Lien, levies and wage garnishments, responsible person investigations, and nominee or alter ego liens. This panel reviews a taxpayer’s right to an administrative appeal of collection enforcement, the procedures for pursuing collection appeals, arguments that can be raised, best practices, and tips of the trade.
Moderator: Jeff Sklarz, Esq., Partner, Green & Sklarz, New Haven, CT
Robbin E. Caruso, CPA, CGMA, Partner, Prager Metis, Cranbury, NJ
Darren John Guillot, National Director, alliantGroup, Washington, DC
Carmela G. Walrond, Esq., Partner, JLD Tax Resolution Group, Union City, NJ
3:30 pm (BREAK)
3:50 - 4:50 pm (BREAK OUT SESSIONS)
TRACK I
ETHICS CREDIT: ARTIFICIAL INTELLIGENCE, CHATGPT & CIRCULAR 230
What exactly is Artificial Intelligence (AI) and how will AI impact tax practice in the future? Join us for an AI demonstration, while we explore the types of AI that are currently available and how they differ from each other. Panelists also address how the IRS is using AI in its enforcement efforts and what tax practitioners should be aware of under Circular 230 and the ABA Model Rules.
Moderator: Andrew Strelka, Esq., Counsel, Latham & Watkins, Washington DC
Benjamin Alarie, Esq., CEO, Blue J; Professor & Osler Chair of Business Law, University of Toronto, Toronto, Canada
Robert J. Kovacev, Esq., Member, Miller & Chevalier, Chartered, Washington, DC
Caitlin R. Tharp, Esq. Associate, Steptoe LLP, Washington, DC
Travis W. Thompson, Esq., Counsel, Boutin Jones, Sacramento, CA
TRACK II
PREPARING FOR INCREASED CRYPTOCURRENCY REGULATION AND ENFORCEMENT IN UNCERTAIN TIMES
The cryptocurrency industry is constantly changing, and its underlying technologies are undeniably confusing. Faced with these obstacles, the IRS has issued informal guidance on discrete and nuanced tax issues and added questions about digital asset transactions to entity tax returns, Treasury has proposed new information reporting rules, and regulatory scrutiny is tightening from all directions. This panel discusses the latest issues involving digital assets and highlights important considerations for tax practitioners.
Moderator: Michelle F. Schwerin, Esq., CPA, Shareholder, Neill Schwerin Boxerman, PC, Clayton, MO
Larry A. Campagna, Esq., Managing Shareholder, Chamberlain, Hrdlicka, White, Williams & Aughtry, PC, Houston, TX
Barbara T. Kaplan, Esq., Shareholder, Greenberg Traurig, New York, NY
Brian C. McManus, Esq., Partner, Latham & Watkins, Boston, MA
Trisha M. Turner, Senior Advisor, Office of the Digital Assets Initiative, Internal Revenue Service, Washington, DC
4:50 pm (CONFERENCE CONCLUDES)
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UPDATES
Stay tuned for agenda updates on the 16th Annual NYU Tax Controversy Forum, which will be held June 27 and 28, 2024 at the Westin New York at Times Square.
