This Year’s Forum To Feature Updates on How the IRS is Enhancing Compliance, Intra-Agency Collaboration, New Penalty and Fraud Referrals, and Its Handling of Tax Collection Challenges
June 22, 2021
NYU School of Professional Studies Division of Programs in Business to Host the 13th Annual Tax Controversy Forum Remotely on June 24 and 25
NEW YORK, June 22, 2020 – This year, the NYU School of Professional Studies (NYU SPS) Division of Programs in Business’ Finance, Law, and Taxation programs will host the 13th Annual Tax Controversy Forum remotely in a shortened format on Thursday, June 24, and Friday, June 25.
“Due to the continued concerns regarding the pandemic, we are looking forward to delivering the same high-quality content that attendees have come to expect from our tax events in virtual format again this year,” said Bryan C. Skarlatos, Esq., Forum co-chair and a partner at Kostelanetz & Fink LLP. “As part of this year’s agenda, expert professionals and government representatives will share their insights, guidance, and best practices on a broad range of issues regarding tax audits and tax litigation at all levels.”
This year’s NYU Tax Controversy Forum will feature updates on what the IRS is doing to enhance compliance through communication and enforcement. Panels will highlight the new IRS focus on intra-agency collaboration, new initiatives with respect to penalties and fraud referrals, and the IRS’ handling of tax collection challenges. Attendees can tune in from their computer, at home or the office, to hear from an exciting array of senior government representatives including:
- Charles P. Rettig, Commissioner, Internal Revenue Service
- Nikole Flax, Commissioner, Large Business & International Division, Internal Revenue Service
- James C. Lee, Chief, Criminal Investigation Division, Internal Revenue Service
- Darren Guillot, Commissioner, Small Business/Self Employed Division, Collection, Internal Revenue Service
- De Lon Harris, Commissioner, Small Business/Self-Employed Division, Examination, Internal Revenue Service
- Douglas W. O’Donnell, Deputy Commissioner for Service and Enforcement, Internal Revenue Service
The Forum, also co-chaired by Steven R. Toscher, Esq., Principal, PC, Hochman Salkin Toscher Perez, PC, is designed for accountants, attorneys, enrolled agents, in-house practitioners, and tax professionals at all levels, who prepare for or handle audits, appeals, or tax litigation, as well as those involved in planning and transactional work. Participants qualify for CPE and CLE credits.
For more information, please contact Kathleen Costello at 212-992-3320 or email email@example.com.
Thursday, June 24, and Friday, June 25, 2021
Thursday, June 24:
12:00 - 1:30 p.m.
A DAY IN THE LIFE: A ROUNDTABLE DISCUSSION WITH SENIOR IRS EXECUTIVES ABOUT IRS OPERATIONAL AND ENFORCEMENT PRIORITIES
The Internal Revenue Service is a dynamic organization that is constantly seeking new ways to further its mission of helping taxpayers comply with the tax law. The past year has been even more challenging than most, forcing a change in work routines and additional responsibilities to implement various stimulus initiatives. Recent proposals to dramatically increase the IRS budget will revitalize the IRS and support its modernization efforts. In this program, senior IRS executives discuss emerging compliance trends and how the IRS charts policy, makes decisions and works synergistically to address non-compliance.
- Charles P. Rettig, Esq., Commissioner, Internal Revenue Service, Washington, DC
- Kevin Q. McIver, Chief of Staff, Internal Revenue Service, Washington, DC
- Douglas W. O’Donnell, CPA, Deputy Commissioner, Services and Enforcement, Internal Revenue Service, Washington, DC
- William M. Paul, Esq., Acting Chief Counsel, Internal Revenue Service, Washington, DC
- Drita Tonuzi, Esq., Deputy Chief Counsel (Operations), Internal Revenue Service, Washington, DC
- Jeffrey Tribiano, Deputy Commissioner for Operations Support, Internal Revenue Service, Washington, DC
1:30 - 2:30 p.m.
ENSURING TAX ACCOUNTABILITY OF LARGE ENTITIES AND WEALTHY TAXPAYERS - CURRENT PRIORITIES AND FUTURE PLANS OF THE LARGE BUSINESS AND INTERNATIONAL DIVISION OF THE IRS
Large Business and International (LB&I) is responsible for tax administration for domestic and international businesses with US tax reporting requirements and assets of $10 million or more, as well as the Global High Wealth and International Compliance programs. This is your chance to meet the new leadership of LB&I and hear about the current state of the compliance campaigns, partnership audit activity, the IRS-wide high income initiative, implementation of the Taxpayer First Act, the International Compliance Assurance Program, and other topics of interest to domestic and multinational entities.
- Sharon Katz-Pearlman, Esq., National Principal-in-Charge, Tax Controversy Services, KPMG, New York, NY; Global Head, Tax Dispute Resolution and Controversy, KPMG International
- Jennifer L. Best Esq., Director, Treaty & Transfer Pricing Operations Practice Area, Internal Revenue Service, Washington, DC
- Nikole C. Flax, Esq., Commissioner, Large Business & International Division, Internal Revenue Service, Washington, DC
- Holly Paz, Esq., Deputy Commissioner, Large Business and International Division, Internal Revenue Service, Washington, DC
3:00 - 4:00 p.m.
FOCUS IN TAX PRACTITIONERS: ETHICAL AND PENALTY ISSUES
Tax practitioners are the gatekeepers to the country’s tax system and are subject to standards and penalties designed to ensure that practitioners give taxpayers clear and impartial advice about how to comply with the tax law. The Office of Professional Responsibility is charged with enforcing these standards and penalties and the IRS recently established the Office of Promoter Investigations to focus on practitioners who promote abusive tax transactions. This panel discusses tax practitioner standards and how the IRS enforces those standards.
- Sandra R. Brown, Esq., Principal, Hochman, Salkin, Toscher & Perez, PC, Beverly Hills, CA
- Jonathan R. Black, Esq., Associate, Caplin & Drysdale, Chartered, Washington, DC
- Lois Deitrich, CPA, Acting Director, Office of Promoter investigations, Small Business/Self-Employed Division, Internal Revenue Service, Washington, DC
- Sharyn M. Fisk, Esq., Director, Office of Professional Responsibility, Internal Revenue Service, Washington, DC
4:00 - 5:00 p.m.
EQUITY, DIVERSITY, AND INCLUSION IN TAX PRACTICE
The United States has more than 150 million taxpayers reporting more than $11 trillion of adjusted gross income each year. This huge group of taxpayers is extremely diverse and the IRS is constantly working to better serve each individual taxpayer. Did you know that the IRS has policies to provide access for taxpayers with limited English proficiency and to make reasonable accommodations for taxpayers with disabilities? In addition, the IRS is subject to laws regarding non-discrimination, civil rights, and equal opportunity. This program addresses issues around bias and discrimination in tax practice, including how to report discrimination by IRS or IRS partners, IRS rules regarding Limited English Proficiency taxpayers, and what to do about preparers who take advantage of immigrant and limited English Proficiency communities.
- Frank Agostino, Esq., President, Agostino & Associates, PC, Hackensack, NJ
- Keisha Clark-Proctor, Associate Director, Civil Rights Unit, Equity, Diversity, and Inclusion Office, Internal Revenue Service, Washington, DC
- Valerie A. Gunter, Chief Diversity Officer, Equity, Diversity, and Inclusion Office, Internal Revenue Service, Washington, DC
5:00 - 6:00 p.m.
TIPS FOR HANDLING AUDITS OF PASS-THROUGH ENTITIES UNDER THE CENTRALIZED PARTNERSHIP AUDIT REGIME
The use of partnerships and other flow-through structures has continued to expand and now accounts for over 50% of all net business income in the United States. With a growing consensus around increased funding for the IRS, a significant uptick in partnership examination activity is expected, focusing particularly on complex ownership arrangements, cross-border activities, and structured transactions. For most, these examinations will be conducted under the new centralized partnership audit regime. For partnerships that elect out the centralized audit regime, the IRS will have to audit, assess, and collect from individual partners. This panel discusses practical topics such as how the IRS links partnership and partner cases in its systems, IRS’ challenges in obtaining statute extensions from all partners, the potential for inconsistent results, and strategies for representing partnerships that have opted out of the centralized audit regime.
- Michael J. Desmond, Esq., Partner, Gibson, Dunn, & Crutcher, Los Angeles, CA
- Megan L. Brackney, Esq., Partner, Kostelnetz & Fink, New York, NY
- Rochelle Hodes, Esq., Principal, Washington National Tax, Crowe, Washington, DC
- Holly Paz, Esq., Deputy Commissioner, Large Business and International Division, Internal Revenue Service, Washington, DC.
Friday, June 25:
12:00 - 1:00 p.m.
HELPING TAXPAYERS MEET THEIR TAX OBLIGATIONS: WHAT’S NEW AT THE SMALL BUSINESS/SELF-EMPLOYED DIVISON OF THE IRS
Small Business/Self-Employed (SB/SE) focuses on approximately 57 million taxpayers that are small businesses with less than $10 million in assets, self-employed individuals, and other taxpayers engaged in business activities. In this panel, the newly-appointed leadership of SB/SE discusses the division’s activities as we evolve out of the pandemic, including its response to the Taxpayer First Act, current and future plans to address non-filing and non-payment of taxes, and enhanced collection activities.
- Eric L. Green., Esq., Partner, Green & Sklarz, New Haven, CT
- Darren John Guillot, Commissioner, Small Business/Self-Employed Division, Collection, Internal Revenue Service, Washington, DC
- De Lon Harris, Commissioner, Small Business/Self Employed Division, Examination, Internal Revenue Service, Washington, DC
1:00 - 1:30 p.m.
NEW LEADERSHIP IN THE TAXPAYER ADVOCATE’S OFFICE: ONE YEAR LATER
On March 30, 2020, just as the pandemic hit, Erin Collins took over as the new National Taxpayer Advocate to lead the Taxpayer Advocate Service (TAS). Before becoming the Taxpayer Advocate, Ms. Collins represented taxpayers before the IRS in private practice and she brings that perspective to TAS. This panel covers the types of matters TAS handles, tips on how to open cases, and the challenges presented by the pandemic, and it provides insight into the role that TAS plays in IRS compliance and enforcement.
- Bryan C. Skarlatos, Esq., Partner, Kostelanetz & Fink, New York, NY
- Erin M. Collins, Esq., National Taxpayer Advocate, Internal Revenue Service, Washington, DC
1:30 - 2:00 p.m.
WHAT’S NEW IN IRS CRIMINAL INVESTIGATIONS
Schemes to defraud the IRS are becoming more complex every day and IRS Criminal Investigation (CI) is responsible for investigating and prosecuting those intent on paying less than their share of tax. CI special agents are trained to use specialized technology to wade through computerized financial records and recover data to help prosecute tax evasion. The globalization of business transactions, the pandemic, and a limited budget have made CI’s job even more challenging. Hear from the former and current Chiefs of IRS CI on how the IRS will meet these challenges and continue to enforce the tax law.
- Don Fort, CPA, Director of Investigations, Kostelanetz & Fink, Washington, DC
- James Lee, Chief, Criminal Investigation Division, Internal Revenue Service, Washington DC
2:00 - 3:00 p.m.
WHAT IS TAX FRAUD AND WHY DOES IT MATTER?
With increased focus on the Tax Gap and IRS enforcement comes renewed emphasis on taxpayer penalties, including civil and criminal fraud penalties. In the past, fraud penalties may have been a consideration of last resort, but now the possible existence of tax fraud will be evaluated whenever taxpayer behavior warrants such a review. Last year, the IRS created the Fraud Enforcement Office to help coordinate the evaluation of unscrupulous taxpayer behavior across divisions of the IRS and determine whether and when civil fraud penalties or referrals for criminal enforcement are appropriate. Hear from senior IRS and DOJ personnel about what they are looking for and how fraud referrals work.
- Sara G. Neill, Esq., Shareholder, Capes, Sokol, Goodman & Sarachan, PC, Saint Louis, MO
- Guy Ficco, Executive Director, Criminal Investigation, Internal Revenue Service, Washington, DC
- Damon Rowe, Esq., Executive Director, Fraud Enforcement Office, Small Business and Self-Employed Division, Internal Revenue Service, Washington, DC
- Carolyn A. Schenck, National Fraud Counsel and Assistant Division Counsel (International), Internal Revenue Service, Rochester, NY
- Olga I. Zverovich, Esq., Assistant United States Attorney, United States Attorney’s Office, Southern District of New York, NY
3:30 - 4:30 p.m.
SHINING A LIGHT ON DIRTY MONEY: CORPORATE TRANSPARENCY AND ANTI-MONEY LAUNDERING ACTS OF 2020
Last year, Congress passed the first major overhaul of the Bank Secrecy Act (“BSA”) in fifty years. The new law requires certain entities to report the identities of their beneficial owners, enhances the government’s ability to obtain foreign bank records, creates new reporting requirements for crypto currencies and antiquities dealers, expands the powers and duties of FinCEN, enhances inter-agency information sharing, and establishes a new whistleblower program for violations of the BSA. This panel explains these new provisions and how they could affect your clients.
- Evan J. Davis, Esq., Principal, Hochman Salkin Toscher Perez PC, Beverly Hills, CA
- Ian M. Comisky, Esq., Partner, Fox Rothschild, Philadelphia, PA
- Deborah L. Connor, Esq., Chief, Money Laundering and Asset Recovery Section, US Department of Justice, Washington, DC
- Andrew Winerman, Esq., Senior Advisor to the Director, Financial Crimes Enforcement Network (FinCEN), Strategic Operations Division, Washington DC
4:30 - 5:30 p.m.
FOCUS ON TAX COLLECTION: HOT TIPS ON DEALING WITH IRS LIENS
A federal tax lien protects the government’s legal claim against a taxpayer’s property and puts other creditors on notice that the taxpayer owes taxes. Tax liens can be devastating to a taxpayer’s personal or business financial affairs. This program explores techniques for dealing with tax liens, such as obtaining a release subordination or withdraw of liens, or a discharge of property subject to a lien. Learn practical tips from expert private practitioners and IRS personnel.
- E. Martin Davidoff, CPA, Esq., Partner-in-Charge - National Tax Controversy Practice, Prager Metis, Cranbury, NJ
- Yvonne R. Cort, Esq., Partner, Capell Barnett Matalon & Schonendeld, Jericho, NY
- Guy Esposito, Advisory Group Manager, Small Business/Self-Employed Division, International Revenue Service, Freehold, NJ
- Alison Gadoua, Tax Controversy Specialist, Prager Metis, Cranbury, NJ
- Dawn Harris, Director, Civil Enforcement Advice and Support Operations, Small Business/Self-Employed Division, Internal Revenue Service, New York, NY
Save the Date for Next Year’s Forum
Next year, the 14th Annual Tax Controversy Forum will take place live and in person on June 23-24, 2022, at the Crowne Plaza Times Square Manhattan, and will feature the same powerful and thought-provoking content that is so critical to those who attend the Forum each year.
About the NYU School of Professional Studies
Celebrating 86 Years of Excellence in Applied Professional Education
For 86 years, the NYU School of Professional Studies (NYU SPS) has been a deeply respected institution of higher education that is grounded in applied learning. From its early years, training returning World War II veterans to fulfill the nation’s urgent need for skilled technical workers, it has evolved into a professional education powerhouse that offers 20 graduate degrees, 13 bachelor’s degrees for traditional and post-traditional students, four associate’s degrees, and a plethora of continuing education courses and credentials.
NYU SPS is a thought leader, and serves as an incubator for new ideas in industries that are constantly changing, including real estate, real estate development, and construction management; hospitality, tourism, travel, and event management; global affairs and global security, conflict, and cybercrime; global sport and sports business; publishing; marketing; public relations; project management; executive coaching and organizational consulting, human resource management and development, and human capital analytics and technology; management and systems; translation; and professional writing. It is focused on building skills that open doors to opportunities in emerging fields and global markets. NYU SPS faculty members are leading experts in their areas of discipline, with a hands-on approach that encourages students to push beyond their limits and to break new ground.
Home to some of the largest and most prestigious industry conferences in the world, including the Schack Institute of Real Estate’s Capital Markets Conference, REIT Symposium, and National Symposium of Women in Real Estate; and the Jonathan M. Tisch Center of Hospitality’s International Hospitality Industry Investment Conference, the School’s invaluable connections to industry leaders is a truly distinguishing factor in the education that it provides. Through career development services and resources provided by the NYU Wasserman Center for Career Development at NYU SPS, guest lecturers, site visits, participation in numerous conferences and events, and Global Field Intensives, students benefit from an NYU education that will set them apart. In addition, they have the opportunity to learn from and network with more than 30,000 NYU SPS alumni who live, work, and contribute to innovation in industry around the world. To learn more about NYU SPS visit: sps.nyu.edu.