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KF Law Annual NYU Forum

14th Annual NYU Tax Controversy Forum
On June 23 And 24, 2022!

In-Person at the Westin New York Grand Central and Livestreaming for Remote Attendees.

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Overview

Kostelanetz & Fink is pleased to sponsor the 2022 NYU Tax Controversy Forum, which will be held on Thursday and Friday, June 23 and 24, 2022, at the Westin New York Grand Central. We will be live and in-person again this year, with the option of livestreaming for remote attendees. Our lineup of speakers is expected to be as robust and interesting as it has been for the past 14 years. An exciting array of senior government representatives and private practitioners will join together to discuss the latest developments in tax compliance and enforcement.
KF Law Forum in NYC
Drita Tonuzi at KF Law Tax Forum
Caroline Ciraolo chatting with attendees at NYC KF LAW tax forum
KF Law Tax Attendees
KF Law: NYU Tax Controversy Forum
NYU Tax Controversy Forum
NYU Tax Controversy Forum
NYU Tax Controversy Forum

Speakers

Featured Speaker

The Honorable Charles P. Rettig, Commissioner of the Internal Revenue Service, will deliver the keynote address at the 2022 14th Annual New York University Tax Controversy Forum.  Please join us to hear Commissioner Rettig’s comments on tax enforcement and priorities at the IRS.   

The Honorable Charles P. Rettig

The Honorable Charles P. Rettig

Other confirmed government speakers include:

Jennifer L. Best, Director, IRS Large Business & International Division, Treaty and Transfer Pricing Operations

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

Thomas A. Cullinan, Acting Chief of Staff to the Commissioner, Internal Revenue Service

Nikole Flax, Commissioner, IRS Large Business & International Division

Danielle Grimm, Special Counsel, IRS Office of Chief Counsel, Passthroughs and Special Industries

Catherine Gugar, Associate Area Counsel, IRS Large Business & International Division

Darren John Guillot, Deputy Commissioner, IRS Small Business/Self-Employed Division, Collection and Operations Support

Scott Irick, Director, IRS Small Business/Self-Employed Division, Examination

The Hon. Kathleen Kerrigan, Chief Judge, United States Tax Court

Andy Keyso, Chief, IRS Independent Office of Appeals

James D. Robnett, Deputy Chief, IRS Criminal Investigation

Thomas J. Sawyer, Senior Litigation Counsel and Counsel for International Tax Matters, Tax Division, U.S. Department of Justice

Benjamin M. Swartz, Senior Advisor to the Commissioner, IRS Small Business/Self-Employed Division, Examination

Tax Controversy Forum Co-Chairs
Bryan C. Skarlatos, Esq., Partner, Kostelanetz & Fink, New York, NY

Bryan C. Skarlatos, Esq.

Partner, Kostelanetz & Fink, New York, NY
Frank Agostino, Esq., Founder and President, Agostino & Associates, P.C., Hackensack, NJ

Frank Agostino, Esq.

Founder and President, Agostino & Associates, P.C., Hackensack, NJ
NYU Tax Controversy Forum
KF Law- About Tax Forum
KF Law- About Tax Forum
KF Law- About Tax Forum

About the Forum

For more than 14 years, the NYU School of Professional Studies Tax Controversy Forum has brought together government representatives and expert private practitioners to share their perspectives on a variety of topics involving federal tax audits, appeals, and litigation. 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.

After two years of holding this premiere event virtually, New York is back and so are we. We’ll be gathering in-person at the Westin New York Grand Central. Located just steps from Grand Central Station, the hotel is nestled in the heart of Manhattan near the Empire State Building, the Chrysler Building, and numerous shops and restaurants surrounding Grand Central. We invite you to come and experience New York City again, all while renewing friendships, networking, and hearing from some of the brightest legal minds in tax. For those who cannot attend in person, we will have the option of livestreaming.

KF Law Forum: westin grand central
NYC Grand Central

Event Location

The Westin New York Grand Central

212 E 42nd St,
New York, NY 10017

Hotel Web Site

NYU TAX CONTROVERSY FORUM 2022
– IN-PERSON and ONLINE PROGRAM
Thursday and Friday, June 23 and 24, 2022

Thursday, June 23rd

8:00 am – 4:45 pm

8:00 - 8:30 am

REGISTRATION, DISTRIBUTION OF MATERIALS, AND CONTINENTAL BREAKFAST

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 find 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 IRS and the DOJ.

8:30 - 8:45 am

WELCOME AND OPENING REMARKS

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

Bryan C. Skarlatos, Esq., Partner, Kostelanetz & Fink, New York, NY

Frank Agostino, Esq., Founder and President, Agostino & Associates, PC, Hackensack, NJ

8:45 - 9:30 am

KEYNOTE ADDRESS: STATE OF THE IRS

Keynote: Charles P. Rettig, Esq., Commissioner, Internal Revenue Service, Washington, DC

9:30 - 10:20 am

STAYING AHEAD OF THE TAX ENFORCEMENT CURVE AND THE NEW EMERGING ISSUES GROUP

Finance, technology, and law are constantly evolving, and tax law is no exception. Taxpayers and their advisors are always on the lookout for new opportunities to reduce taxes. This panel will explain how the IRS keeps up with the changing profile of tax avoidance and tax evasion. The panel will also introduce the IRS’ new Emerging Issues Group and describe how it will go about discovering and confronting the latest transactions designed to avoid or evade tax.

Moderator: Michelle F. Schwerin, Esq., CPA, Shareholder, Capes, Sokol, Goodman & Sarachan, PC, St. Louis, MO

Thomas A. Cullinan, Esq., Acting Chief of Staff to the Commissioner, Internal Revenue Service, Washington, DC

Danielle M. Grimm, Special Counsel, IRS Office of Chief Counsel: Passthroughs and Special Industries, Washington, DC

Benjamin M. Swartz, Senior Advisor to the Commissioner, IRS Small Business/Self-Employed Division, Examination, Washington, DC

10:20 - 10:40 am (BREAK)

10:40 - 11:30 am

IRS LARGE BUSINESS & INTERNATIONAL DIVISION ENFORCEMENT UPDATE

The IRS continues to refine its focus on large taxpayers, which tend to have complicated issues and examinations. This panel will discuss a number of initiatives that directly impact the LB&I taxpayer, including an update on the Compliance Assurance Process (“CAP”), which allows eligible taxpayers to undergo a real-time pre-filing audit; the status of Rev. Proc. 94-69, which allows large corporate taxpayers to disclose certain tax issues after the opening of an examination; LB&I’s application of the recent Chief Counsel Advice addressing the documentation requirements for research credit claims; and LB&I’s presence at Appeals conferences. The discussion will also address the IRS’ current partnership initiatives and recent developments in transfer pricing.

Moderator: Sharon Katz-Pearlman, Esq., National Principal-in-Charge, Tax Dispute Resolution Network, KPMG, New York, NY; Global Head, Tax Dispute Resolution and Controversy, KPMG International

Jennifer L. Best, Esq., Director, IRS Large Business & International Division, Treaty and Transfer Pricing Operations, Washington, DC

Nikole Flax, Esq., Commissioner, IRS Large Business & International Division, Washington, DC

11:30 - 12:00 pm

DEPARTMENT OF JUSTICE TAX DIVISION ENFORCEMENT UPDATE

Moderator: Barbara T. Kaplan, Esq., Shareholder, Greenberg Traurig, New York, NY

Thomas J. Sawyer, Esq., Senior Litigation Counsel and Counsel for International Tax Matters, Tax Division, U.S. Department of Justice, Washington, DC

12:00 - 1:30 pm (LUNCH)

1:30 - 2:30 pm

WHO NEEDS TAX RULES AND REGULATIONS? THE SURPRISING WAYS THE ADMINISTRATIVE PROCEDURE ACT IS AFFECTING TAX PRACTICE

Our tax system is based on extremely complex rules and regulations which govern how taxes must be reported and paid. The Administrative Procedure Act generally requires the Treasury Department to follow specific procedures designed to give the public notice and an opportunity to comment before certain kinds of rules and regulations are enacted. Recent court decisions have invalidated IRS notices for failure to follow these procedures and have allowed taxpayers to seek injunctions against the IRS in limited situations. This panel will discuss these decisions and their impact on current audits and litigation as well as the IRS’ authority to enforce existing rules and regulations.

Moderator: John Colvin, Esq., Partner, Colvin + Hallet Law, Seattle, WA

David W. Foster, Esq., Partner, Skadden, Arps, Slate, Meagher & Flom, Washington, DC

Jenny L. Johnson, Esq., Partner, McDermott Will & Emery, Chicago, IL

Kevin L. Kenworthy, Esq., Member, Miller & Chevalier, Washington, DC

2:30 - 3:30 pm

FROM THE FRYING PAN AND INTO THE FIRE: HANDLING AUDITS UNDER THE NEW CENTRALIZED PARTNERSHIP AUDIT REGIME

Audits of partnerships and other pass-through entities were previously governed by special procedures under the Tax Equity and Fiscal Responsibility Act (“TEFRA”). For tax years 2018 and forward, however, audits of partnerships and pass-throughs will be governed by the new Centralized Partnership Audit Regime. The new regime will dramatically change the way audits are handled and practitioners must understand the new rules to effectively represent their clients and avoid costly mistakes. This panel will discuss the new regime and the complexities of transitioning from TEFRA. The panel will also suggest ways to prepare for and effectively manage a partnership audit under the new rules.

Moderator: Megan L. Brackney, Esq., Partner, Kostelanetz & Fink, New York, NY

Rochelle Hodes, Esq., Principal, Crowe LLP, Washington, DC

Amanda H. Nussbaum, Esq., Partner, Proskauer Rose, New York, NY

Joy Gerdy Zogby, Esq., Senior Technician Reviewer, IRS Office of Chief Counsel, Procedure and Administration, Washington, DC

3:30 - 3:45 pm (BREAK)

3:45 - 4:45 pm

TIPS FOR CONTESTING FOREIGN ASSET REPORTING PENALTIES

The IRS automatically assesses penalties for foreign asset information returns that it considers delinquent or incomplete. The mistakes that give rise to these failures are often very minor compared to the amount of the penalties assessed. Under current IRS procedures, the only pre-payment remedy is to rely on the IRS to exercise its discretion to abate the penalties based on reasonable cause. This panel will provide tips for navigating the penalty abatement process to help taxpayers avoid incurring significant penalties for relatively minor foot faults.

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

Richard J. Sapinski, Esq., Member, Sills Cummis & Gross PC, Newark, NJ

Thomas J. Sawyer, Esq., Senior Litigation Counsel and Counsel for International Tax Matters, Tax Division, U.S. Department of Justice, Washington, DC

Philip J. Wilson, CPA, Office Managing Partner, Marcum, Costa Mesa, CA

Friday, June 24th

8:00 am – 5:00 pm

8:00 - 9:00 am

REGISTRATION, DISTRIBUTION OF MATERIALS, 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 find 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.

9:00 - 9:30 am

IRS CRIMINAL INVESTIGATION ENFORCEMENT UPDATE

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

James D. Robnett, Deputy Chief, IRS Criminal Investigation, Washington, DC

9:30 - 10:00 am

IRS SMALL BUSINESS/SELF-EMPLOYED DIVISION ENFORCEMENT UPDATE

Moderator: Eric L. Green, Esq., Partner, Green & Sklarz, New Haven, CT

Darren John Guillot, Deputy Commissioner, IRS Small Business/Self-Employed Division, Collection and Operations Support, Washington, DC

Scott Irick, Director, IRS Small Business/Self-Employed Division, Examination, Washington, DC

10:00 - 10:30 am

IRS INDEPENDENT OFFICE OF APPEALS UPDATE

Moderator: Todd Welty, Esq., President and CEO, Todd Welty PC, Atlanta, GA

Andy Keyso, Esq., Chief, IRS Independent Office of Appeals, Washington, DC

10:30 - 11:00 am

IRS OFFICE OF CHIEF COUNSEL UPDATE

Moderator: Brian W. Kittle, Esq., Partner, Mayer Brown, New York, NY

Catherine Gugar, Esq., Associate Area Counsel, IRS Large Business & International Division, Washington, DC

11:00 - 11:15 am (BREAK)

11:15 - 11:45 am

U.S. TAX COURT UPDATE

Moderator: Michael J. Desmond, Esq., Partner, Gibson, Dunn & Crutcher, Los Angeles, CA and Washington, DC

The Hon. Kathleen Kerrigan, Chief Judge, United States Tax Court, Washington, DC

11:45 am - 12:15 pm

NATIONAL TAXPAYER ADVOCATE UPDATE

Moderator: Josh O. Ungerman, Esq., CPA, Partner, Meadows, Collier, Reed, Cousins, Crouch & Ungerman, Dallas, TX

Erin M. Collins, Esq., National Taxpayer Advocate, Washington, DC

12:15-1:45 pm (LUNCH)

1:45 - 2:45 pm

FINDING HIDDEN MONEY: REPORTING CRYPTOCURRENCY, DISCLOSING OWNERSHIP OF SHELL CORPORATIONS, AND THE NEW ANTI-MONEY LAUNDERING ACT

On January 1, 2021, Congress passed the new Anti-Money Laundering Act, ushering in the most sweeping changes to the Bank Secrecy Act and other anti-money laundering laws since 2001. The new Act beefs up the government’s ability to prosecute those engaged in dirty money transactions, imposes new reporting requirements for nontraditional assets held abroad (including cryptocurrency), and requires disclosure of the beneficial owners of shell corporations. This panel will explain these new rules and how they could affect your clients.

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

Andrew Adams, Esq., Director, KleptoCapture Task Force; Co-Chief, Money Laundering & Transnational Criminal Enterprises, U.S. Attorney’s Office, Southern District of New York, New York, NY

Sarah E. Paul, Esq., Partner, Eversheds Sutherland, New York, NY

Jeremy H. Temkin, Esq., Principal, Morvillo Abramowitz Grand Iason & Anello PC, New York, NY

2:45 - 3:45 pm

COMING IN FROM THE COLD: THE FUTURE OF VOLUNTARY DISCLOSURES

For more than 70 years, the IRS maintained a voluntary disclosure policy designed to encourage taxpayers to come in from the cold and self-report noncompliance. In 2018, the voluntary disclosure program was updated to provide new procedures. In its most recent annual report, the Taxpayer Advocate Service noted that the new procedures are substantially more onerous and uncertain than the old procedures, and may actually discourage taxpayers from stepping forward to self-disclose. This panel will discuss the latest voluntary disclosure developments, including the application of the updated program to cryptocurrency, and provide suggestions on how practitioners should advise their clients to make the best use of the new voluntary disclosure procedures.

Moderator: Phillip Colasanto, Esq., Associate, Agostino & Associates, PC, Hackensack, NJ

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

Mark Matthews, Esq., Member, Caplin & Drysdale, Washington, DC

Michel R. Stein, Esq., Principal, Hochman Salkin Toscher Perez, PC, Beverly Hills, CA

3:45 - 4:00 pm (BREAK)

4:00 - 5:00 pm

CONFESSIONS OF A TAX EVADER: RESOLVING CRIMINAL TAX CASES WITH GUILTY PLEAS

IRS Criminal Investigation and the DOJ Tax Division have an impressive conviction rate. As a result, many taxpayers who are the target of a criminal investigation or who have been indicted are well served to consider resolving their prosecution with a guilty plea. This panel will examine some of the considerations that go into deciding whether a taxpayer should plead guilty and the techniques for negotiating the plea. In addition, a taxpayer who recently pleaded guilty will discuss his reasons for doing so.

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

Scott S. Ahroni, Esq., Shareholder, Polsinelli PC, New York, NY

Alan M. Katz, CPA, CFF (with former cooperating defendant), Senior Forensic Auditor, Monitoring and Investigations Practice, Guidepost Solutions, New York, NY

Olga Zverovich, Assistant United States Attorney and Tax Coordinator, U.S. Attorney’s Office, Southern District of New York, New York, NY

UPDATES

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Bryan Skarlatos speaking at KF Law Tax Forum in NYC
KF Law Tax Forum 2022 co-chairs Bryan and Frank Agostino with another attendee
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