7:30 – 8:30 am:

Breakfast / Registration

8:30 – 8:35 am:

Opening Remarks / Housekeeping Items

8:35 – 10:00 am:

IRS Update

Hear directly from the IRS Executives what to expect from the IRS this coming year.

SB/SE Update:

• SB/SE Commissioner Amalia C. Colbert (invited)
• Interviewed by Jeffrey M. Sklarz, Esq., Green & Sklarz LLC, New Haven, CT

Independent Office of Appeals Update:                              

• Andy Keyso, Chief of Appeals
• Interviewed by G. Michelle Ferreira, Esq., Greenberg Traurig LLP, San Francisco, CA

National Taxpayer Advocate Update:          

• Erin Collins, National Taxpayer Advocate (Invited)
• Interviewed by Lisa E. Perkins, Esq., Green & Sklarz LLC, West Hartford, CT

10:00 – 10:10 am:

Break

10:10 – 11:00 am:

Enforcement Trends: Crypto, Conservation Easements, Micro-captives, Marijuana – What’s Hot and What’s Not!

Our panel will review the current trends in IRS enforcement, discuss the IRS Dirty Dozen and latest LB&I Campaigns, and what to expect in the coming year.

Moderator:   

• Guinevere M. Moore, Esq., Moore Tax Law Group, LLC, Chicago, IL

Panelists:   

• Daniel Mayo, Esq., Withum, Smith & Brown, PC, Red Bank, NJ
• Victor A. Jaramillo, Esq., Caplin & Drysdale, Washington, DC
• Richard Tierney, Deputy Director of Exam, Internal Revenue Service, Boston, MA

11:00 – 12:00 pm:

Ethics: The Ethical Issues Around Whistleblowing: Can We or Can’t We?

According to the Commissioner, our nation’s tax gap is approximately $1 trillion. While a portion of the gap is attributable to taxpayers who are simply unable to pay tax due and owing, much of the gap is the result of intentional conduct – abusive transactions, false returns, evasion of assessment, evasion of payment, and other knowing violations. What can you do if your client knows about tax crimes being committed under their watch? They can strike a blow for justice, help the American tax system, and get paid to do it. Nothing more American than that!  But what if the target is a client?  Can we ethically blow the whistle on a client, former client, potential client, or related third parties?  Our panel of experts will review the whistleblower program and discuss the various ethical issues surrounding both representing the whistleblower as well as becoming a whistleblower yourself, and what you can and cannot do.

Moderator:     

• Eric L. Green, Esq., Green & Sklarz LLC, New Haven, CT

Panelists:

• Walter Pagano, CPA, CFE, Eisner Advisory Group LLC, New York, NY
• Michael A. Villa, Jr., Esq., Meadows, Collier, Reed, Cousins, Crouch & Ungerman, LLP, Dallas, Tx
• Karen L. Hawkins, Esq., Attorney-At-Law, Yachats, OR

12:00 – 12:45 pm:

Lunch

12:45 –1:45 pm:

Track A: The Tax and Non-Tax Pitfalls of Liquidating the Business

Remember that new business venture where everyone was ready to launch the next Amazon?  Guess what?  Things did not go quite as well as they had hoped, and now the business, business relationships, and even their own financial plans are quickly dissolving into a mess and the closing of the business.  Our panel will discuss the various tax and non-tax issues clients will need to face when the business breaks up and how practitioners can help their clients navigate the situation and avoid it becoming more of a mess than it already is.

Moderator:     

• Jason A. Marsh, Esq., Green & Sklarz LLC, New Haven, CT

Panelists:  

• Stuart Katz, Esq., Cohen & Wolf, PC, Bridgeport, CT
• Robert Turnipseed, Esq., Ambrecht Jackson LLP, Mobile, AL
• Michele A. Lazzara, CPA, CGMA, CBIZ Marks Paneth, White Plains, NY

Track B: Estate & Gift Update Part 1: IRS Challenges to Your Client’s Best-Laid Plans

SLATs, GRATs, IDGTs and ILITs.  Terrific planning techniques that, when set up and managed correctly, can save millions of dollars in estate taxes and transfer the family business and wealth to the next generation.  What happens when the IRS and/or state tax authorities show up and disagree? Our panel will review issues surrounding the most popular estate planning techniques and what practitioners should look for when clients decide to get their “financial house” in order and do their planning, and what to do when the letter from Uncle Sam arrives to review the planning.

Moderator:  

• Lawrence A. Sannicandro, Esq., McCarter & English, LLP, Newark, NJ

Panelists:  

• Kristin M. Lynn, Esq., Green & Sklarz LLC, New Haven, CT
• Anthony F. Vitiello, Esq., Connell Foley, Roseland, NJ
•  Barry Fischman, CPA, Marcum LLP, New Haven, CT

1:45 – 2:45 pm:

Track A: 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, partnership and pass-through audits will be governed by the new Centralized Partnership Audit Regime. The new regime are dramatically changing 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 governing partnership and pass-through audits and the complexities of transitioning between TEFRA and the new rules. The panel will also suggest ways to prepare for and effectively manage a partnership audit under the new rules.

Moderator: 

• Caroline D. Ciraolo, Esq., Kostelanetz & Fink, LLP, Washington, DC

Panelists: 

• Philip J. Wilson, CPA, Marcum, LLP, Costa Mesa, CA
• Steven Hurok, Esq., Citrin Cooperman & Company LLP, New York, NY
• G. Michelle Ferreira, Esq., Greenberg Traurig LLP, San Francisco, CA

Track B: Estate & Gift Update Part 2: Pitfalls When Handling the Estate and Why the Tax Returns Matter!

Hidden offshore bank accounts, a second set of books, unreported taxable gifts, and fraudulent income tax returns. Pitfalls for the unwary practitioner attempting to assist clients with probating their loved-one’s estate.  This program will cover the key issues that need to be addressed, the questions that should be raised, and best practices in remediating past misdeeds.  The program will also cover the obligations of executors and administrators under the Federal Priority Act that must be satisfied prior to any distributions to avoid personal liability for those pesky tax issues.

Moderator: 

• Zhanna A. Ziering, Esq., Moore Tax Law Group, New York, NY

Panelists:   

• Frank Agostino, Esq., Agostino & Associates, Hackensack, NJ
• Kristin M. Lynn, Esq., Green & Sklarz LLC, New Haven, CT

2:45 – 3:00 pm:

Break

3:00 – 4:00 pm:

Track A: Representing Clients Before a Resource-Challenged IRS

The challenges of dealing with the IRS persist and have now drawn the attention of Congress.  Our panel will review the ongoing issues and what practitioners should be doing with the IRS after filing returns, including the IRS’s suspension of sending certain letters and what that actually means, tax returns that have yet to be processed, resolving disputes over the child tax credit and reconciliation with the Advance CTC, tax liens and payoff letters, and Freedom of Information Act Request responses, among other issues.

Moderator:     

• Amanda Evans, EA, Green & Sklarz LLC, New Haven, CT

Panelists: 

• Nina E. Olson, Esq., Center for Taxpayer Rights, Washington, DC
• Sara V. Spodick, Esq., Quinnipiac University Law School, North Haven, CT
• David A. Shuster, Esq., Marcum LLP, New York, NY

Track B: Defending You! Preparer Penalties and Referrals to the OPR

IRS examiners have become very aggressive in pursuing preparer and appraisal penalties when it believes the professional crossed the line. This decision to penalize the professional can be for anything from disagreeing with the valuation you arrived at or even failing to file your own tax returns. These penalties, once paid, will lead to an automatic referral to the IRS Office of Professional Responsibility. The panelists will review the commonly assessed civil penalties, the assessment procedure and applicable statutes of limitations, the right to and procedure for administrative and judicial appeals, and what steps to take with respect to an OPR referral.

Moderator: 

• Eric L. Green, Esq., Green & Sklarz LLC

Panelists: 

• Karen L. Hawkins, Esq., Attorney-At-Law, Yachats, OR
• Guinevere M. Moore, Esq., Moore Tax Law Group, LLC, Chicago, IL
• Sanford J. Boxermann, Esq., Capes, Sokol, Goodman & Sarachan, PC, St. Louis, MO

4:00 – 5:00 pm:

Track A: 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. The panel will also review the impact of tax loss and why the role of the Kovel accountant is so critical.

Moderator: 

• Michael A. Villa, Jr., Esq., Meadows, Collier, Reed, Cousins, Crouch & Ungerman, LLP, Dallas, TX

Panelists: 

• Anastasia King, Esq., Asst. United States Attorney, Department of Justice, New Haven, CT
• Barbara T. Kaplan, Esq., Greenberg Traurig LLP, New York, NY
• Damon Rowe, Esq., Meadows, Collier, Reed, Cousins, Crouch & Ungerman, LLP, Dallas, TX

Track B: Gotcha! Challenging Tax Penalties on International Forms

In 2018, the IRS began to automatically assess civil penalties for the failure to file or to accurately file foreign international information returns, including but not limited to Forms 5471, 5472, 8865, 8938, 926, 3520, and 3520A. 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:     

• Zhanna A. Ziering, Esq., Moore Tax Law Group, New York, NY

Panelists: 

• Miri Forster, Eisner Advisory Group LLC, New York, NY
• Laura L. Gavioli, Esq., Alston & Bird, LLP, New York, NY
• Sanessa S. Griffiths, Esq., Skadden, Arps, Slate, Meagher & Flom, LLP, Washington, DC