18th Annual Tax Controversy Forum 2026 – Track III (Presented by NYU School of Professional Studies)

Caroline D. Ciraolo, Esq., Partner | Kostelanetz

Caroline D. Ciraolo, former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division, is a partner with Kostelanetz LLP and founder of its Washington, D.C. office. Her practice focuses on federal and state civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, and representing individuals and entities in criminal tax investigations and prosecutions. She also serves as a consulting and testifying expert witness and as an independent mediator in tax-related administrative proceedings and litigation. 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 across 14 civil, criminal, and appellate sections.

• Education & Credentials

Caroline earned an LL.M. in Taxation from the University of Baltimore School of Law in 1994, a J.D. with Honors from the University of Maryland School of Law in 1993, and a B.S. in Finance with Honors, cum laude, from The College of New Jersey in 1990. She is admitted to practice in Maryland (1993), Pennsylvania (1995), New Jersey (1995), and the District of Columbia (1995). Her court admissions include the U.S. Tax Court; the U.S. District Court for the District of Maryland; the U.S. Court of Federal Claims; the U.S. Courts of Appeals for the Second, Fourth, Ninth, and Federal Circuits; and the U.S. Supreme Court.

• Recognition & Leadership

Caroline is recognized by Chambers for USA: Tax Fraud (Nationwide) (Band 1), Tax Controversy – Nationwide (Band 2), District of Columbia: Tax (Band 1), and High Net Worth: Tax-Private Client – USA (Band 1). She is named a Leading Lawyer by Legal 500 and is recognized by Benchmark Litigation, ITR World Tax (Tax Controversy, World Tax – Highly Regarded, and Women in Tax Leader), and Super Lawyers in both D.C. and Maryland (including Top 10 in Maryland and a Maryland cover story in 2013). She is recognized in Best Lawyers in America for Litigation and Controversy – Tax, Tax Law, and Criminal Defense: White Collar, and has been named Lawyer of the Year for Litigation and Controversy – Tax (D.C. 2022, 2024, and 2026; Maryland 2012) and for Tax Law (D.C. 2025). She received the Euromoney Legal Media Group’s Americas Women in Business Law Awards (Best in Tax Dispute Resolution) (2014) and was named to The Daily Record’s Top 100 Women Circle of Excellence. She is also a recipient of the ABA Section of Taxation’s Janet Spragens Pro Bono Award, the IRS Chief Counsel Award (the highest honor that office can confer), and the Tax Excellence Award from the Taxation Section of the Maryland State Bar Association.

• Professional Involvement

Caroline is former President of the American College of Tax Counsel and former Chair of the Civil & Criminal Tax Penalties Committee of the American Bar Association Section of Taxation. She served as the ABA Tax Section’s inaugural Vice Chair for Membership, Diversity, and Inclusion, and inaugural Chair of the Loretta Collins Argrett Fellowship Program. She is a Fellow of the American College of Tax Counsel (Immediate Past President 2021-2022, Vice President 2020-2021, Secretary/Treasurer 2018-2020, and Regent for the 4th Circuit 2017-2018) and a Fellow of the Litigation Counsel of America and the Maryland Bar Foundation. She also served as an instructor with the IRS Military Volunteer Income Tax Assistance program at Ft. George G. Meade. She is an Adjunct Professor at the Georgetown University Law Center, teaching International Tax Controversies and Criminal Tax Law and Procedure, and previously taught Tax Practice and Procedure and Criminal Tax in the University of Baltimore School of Law Graduate Tax Program.

• Experience

Caroline served as Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division (February 25, 2015 – July 15, 2016), as well as Principal Deputy Assistant Attorney General (January 12, 2015 – January 20, 2017), Deputy Assistant Attorney General for Criminal Matters (October 5, 2015 – January 20, 2017), and Deputy Assistant Attorney General for Policy and Planning (January 12, 2015 – January 20, 2017). During her tenure, she was actively involved in all aspects of Tax Division operations and was responsible for approximately 500 employees, including more than 360 attorneys across 14 civil, criminal, and appellate sections. Earlier in her career, she served as Attorney Advisor to the Honorable Stanley J. Goldberg of the U.S. Tax Court (August 1994 – August 1996) in Washington, D.C. As a partner with Kostelanetz LLP and founder of its Washington, D.C. office, her practice focuses on federal and state civil tax controversies, sensitive audits, administrative appeals, litigation, internal investigations, and criminal tax investigations and prosecutions, and she serves as a consulting and testifying expert witness and independent mediator in tax-related matters.

 

Michael J. Desmond, Esq., Member and Tax Department Chair| Miller & Chevalier, Chartered

Michael J. Desmond is a Member at Miller & Chevalier, where he serves as Chair of the Tax practice and Practice Co-Lead of Tax Controversy & Litigation. His practice covers a broad range of federal tax matters with a focus on administrative tax policy, tax controversy, and litigation. He represents clients in approaches to the Internal Revenue Service (IRS) and the U.S. Department of the Treasury on administrative rulemaking matters and matters relating to tax administration and enforcement, seeking clarity on the application of federal tax laws. He also represents clients before the examination divisions of the IRS, the IRS Independent Office of Appeals, and in the U.S. Tax Court, federal district courts, the Court of Federal Claims, and federal courts of appeal. His clients have included businesses and individuals across a wide range of industries, including real estate, financial services, publishing, technology, medical services and devices, and entertainment. Clients quoted in Chambers USA have described him as “very smart, strategic, and knowledgeable of tax law,” “responsive and insightful,” noting that his knowledge of complex matters is incredibly valuable.

• Education & Credentials

Mike earned his J.D., magna cum laude, from The Catholic University of America, Columbus School of Law in 1994, where he served as Executive Editor of the Catholic University Law Review. He received his B.A. from the University of California, Santa Barbara in 1990. He is admitted to practice in California, the District of Columbia, and New York. His court admissions include the United States Tax Court; the U.S. Courts of Appeals for the Federal, Fourth, Seventh, Ninth, and Tenth Circuits; the U.S. District Courts for the District of Columbia, the Central District of California, and the Northern District of California; and the U.S. Court of Federal Claims.

• Recognition & Leadership

Mike has been recognized in The Best Lawyers in America® for Tax Law from 2012 through 2025 and was named Lawyer of the Year for Tax Litigation and Controversy in 2023. He is ranked in Chambers High Net Worth USA for Tax: Private Client (Nationwide) from 2023 through 2025 and in Chambers USA for Tax: Controversy (Nationwide) from 2008 through 2019 and 2023 through 2025. He is recognized by Legal 500 for Tax: U.S. Taxes: Contentious from 2008 through 2018 and 2022 through 2025, including Hall of Fame honors in 2024 and 2025, and was named to the Lawdragon: 500 Leading Global Tax Lawyers Guide in 2025. His government service was recognized with the IRS Commissioner’s Award (2008, 2021), the IRS Chief Counsel’s Award (2008), the Treasury Secretary’s Honor Award (2007), and the U.S. Department of Justice, Tax Division Award for Sustained Superior Performance (1998).

• Professional Involvement

Mike currently serves as President of the American College of Tax Counsel and as Vice Chair of Government Relations for the Tax Section of the American Bar Association. He is a former Chair of the Committee on Government Submissions, the Standards of Tax Practice Committee, and the Tax Shelters Committee within the ABA Tax Section, and he serves as a Trustee of the Southern Federal Tax Institute. He previously served as an adjunct professor at Georgetown University Law Center and has been a guest lecturer at law schools around the country.

• Experience

Prior to joining Miller & Chevalier, Mike was a partner with a global law firm. Before that, he served as the 48th Chief Counsel of the IRS, nominated by the president and confirmed by the Senate, where he was the principal legal officer for the IRS, overseeing a staff of nearly 1,500 lawyers responsible for interpreting and advising on all aspects of federal tax law. During his tenure, the Office issued more than 100 sets of proposed and final regulations implementing the Tax Cuts and Jobs Act of 2017 and published dozens of guidance items relating to the COVID-19 pandemic, while litigating nearly 25,000 cases pending in the U.S. Tax Court and working with the DOJ Tax Division on cases in other courts, including the U.S. Supreme Court. He previously served as Tax Legislative Counsel at the Treasury, the principal legal advisor to the Secretary and Assistant Secretary (Tax Policy) on all domestic aspects of federal tax law other than employee benefits, working closely with the congressional tax writing committees. Earlier in his career, he served as a Trial Attorney in the DOJ Tax Division, litigating dozens of cases throughout the western U.S., and as a law clerk to the Honorable Ronald S.W. Lew of the U.S. District Court for the Central District of California. In private practice, he has been counsel of record in numerous docketed tax matters, litigating many to published decision on issues including transferee liability, debt versus equity treatment of partnership investments, the “property for services” rules, partnership refund claim requirements, fraud penalties, and the valuation of customer-based intangibles

 

Hon. Frank J. Bisignano, Chief Executive Officer | Internal Revenue Service

Hon Frank J. Bisignano is the first Chief Executive Officer of the Internal Revenue Service, managing an agency that collected approximately $5.1 trillion in tax revenue in Fiscal Year 2024 — revenue that consistently generates about 96% of the funding that supports the federal government’s operations each year. He brings to this role extensive leadership experience from several decades in the financial services sector. Widely recognized for his expertise in operational management and technology innovation, he has consistently driven growth, improved customer service, and led complex organizations through modernization and digital transformation. As IRS CEO, he works to advance the IRS mission by sharpening its focus on three priorities: improving collections, safeguarding privacy, and enhancing customer service — goals that guide how the agency delivers better outcomes for taxpayers and strengthening the IRS for the future.

• Recognition & Leadership

Mr. Bisignano is widely recognized for his expertise in operational management and technology innovation, and throughout his career he has consistently driven growth, improved customer service, and led complex organizations through modernization and digital transformation. He started his career on Wall Street and became the youngest Senior Vice President of Shearson Lehman/American Express at age 25. Following the September 11, 2001 attacks on New York’s World Trade Center, during which he was with Citigroup, he led the relocation of more than 16,000 displaced Citigroup employees and became a founding member and board leader of the 9/11 Memorial & Museum.

• Professional Involvement

Alongside his duties as IRS CEO, Mr. Bisignano continues to serve as the Commissioner of the Social Security Administration, a position he assumed in May 2025, where he has taken swift action to transform that agency into a premier service organization delivering best-in-class service to the American people. He also serves as a founding member and board leader of the 9/11 Memorial & Museum.

• Experience

Prior to his government service, Mr. Bisignano was CEO of Fiserv, the world’s largest financial services and payment technology company. Before Fiserv, he was the Chairman and CEO of First Data, where he transformed the 43-year-old company into a technology innovator, industry collaborator, and commerce enabler for the 21st century. He started his career on Wall Street and was the youngest Senior Vice President of Shearson Lehman/American Express at age 25. He later became the co-Chief Operating Officer for J.P. Morgan Chase and the CEO of its Mortgage Banking unit. He also held several roles at Citigroup, and was with Citigroup on September 11, 2001, when terrorists attacked New York’s World Trade Center; in the aftermath, he led the relocation of more than 16,000 displaced Citigroup employees.

 

Sharon Katz-Pearlman, Esq., Shareholder | Greenberg Traurig

Sharon Katz-Pearlman is a Shareholder at Greenberg Traurig, LLP, based in New York, who focuses her practice on the representation of large multinationals, partnerships, high-wealth individuals, and other taxpayers before the Internal Revenue Service (IRS) on both domestic and cross-border issues, across all industries. She represents clients from the pre-exam phase — including voluntary disclosures and pre-filing agreements — through examination, appeals, and into litigation if necessary, and has wide-ranging experience with resolution of transfer pricing issues at the examination and IRS Appeals level as well as with Competent Authority proceedings, seeking a Mutual Agreement Procedure (MAP) agreement and/or an Advanced Pricing Agreement (APA). In addition to traditional representation before the IRS, she represents clients using the full range of IRS Alternative Dispute Resolution tools, advises large companies on the IRS’s Compliance Assurance Program (CAP) and other IRS specialty programs, and advises clients on application to and participation in the OECD’s International Compliance Assurance Programme (ICAP) process. She is a member of the firm’s Tariff Task Force, a multidisciplinary initiative that guides clients through tariff refund matters, tax, litigation, and
M&A activity spurred by global shifts. Sharon brings over 30 years of experience in federal tax controversy, gained in both private and government practice.

• Education & Credentials

Sharon earned an LL.M. from New York University School of Law, a J.D., cum laude, from the Benjamin N. Cardozo School of Law, and a B.A., cum laude, from Barnard College, Columbia University. She is admitted to practice in New York and before the U.S. Tax Court.

• Recognition & Leadership

Sharon has been shortlisted by The Legal Benchmarking Group for its “Women in Business Awards,” including North America Transfer Pricing Lawyer of the Year (2026) and North America Tax Lawyer of the Year (2025). She is listed in The Best Lawyers in America for Tax Law (2025-2026) and in Lawdragon’s “500 Leading Global Tax Lawyers” (2025). She is recognized by International Tax Review as a “Controversy Leader” in its Comprehensive Guide to the World’s Leading Tax Controversy Advisors, in its Women in Tax Leaders Guide (2025-2026), and as a World Tax Leader, and is listed in Euromoney’s Expert Guides for “Women in Business Law.” While with the IRS Office of Chief Counsel, she earned the National Attorney of the Year Award, given annually to one attorney for outstanding contribution to the Office.

• Professional Involvement

Sharon is a Fellow of the American College of Tax Counsel and an Adjunct Professor of Law at NYU Law School, where she teaches Civil Tax Controversies & Litigation. She is a former member (four-year term) of the United Nations Tax Subcommittee on Dispute Avoidance, Resolution and the Mutual Agreement Process, under the direction of the United Nations Committee of International Tax Experts on International Cooperation in Tax Matters. She serves on the Board of Overseers of the Cardozo School of Law, Yeshiva University (2023-Present), and has served on the Law360 Tax Authority Federal Editorial Advisory Board (2024) and International Editorial Advisory Board (2023). She is a member of the National Association of Women Lawyers, the American Bar Association, the New York State Bar Association, and the Federal Bar Association. She is often quoted in tax publications such as Tax Notes and frequently speaks on tax controversy topics at industry conferences including the Tax Executives Institute (TEI), the American Bar Association (ABA), the Practicing Law Institute (PLI), the NYU Tax Controversy Forum, and the Tax Council Policy Institute (TCPI).

• Experience

Immediately prior to joining Greenberg Traurig, Sharon served as the national and global practice leader of the Tax Controversy & Dispute Resolution practice at a Big Four accounting firm. She was with KPMG, LLP from 1993 to 2022, where she held roles including Co-National Principal in Charge, Tax Controversy & Dispute Resolution, Washington National Tax; National Principal in Charge, Tax Controversy & Dispute Resolution; Northeast Area Principal in Charge, Tax Controversy Services; and Senior Manager, Tax Controversy Services. From 2008 to 2022, she served as Global Head of the Tax Dispute Resolution and Controversy Network at KPMG International. Earlier in her career, she was a litigator for the IRS Office of Chief Counsel from 1986 to 1993, serving as a Special Litigation Attorney (and recipient of the National Attorney of the Year Award in 1989) as well as a Trial Attorney/Senior Trial Attorney. She has served as an Adjunct Professor of Law in the LLM Program at New York University School of Law from 2017 to the present.

 

Lia Colbert, Commissioner, Small Business/Self-Employed Division | Internal Revenue Service

Amalia “Lia” Colbert serves as Commissioner of the Small Business/Self-Employed (SB/SE) Division of the Internal Revenue Service. In this role, she oversees taxpayer programs and services affecting the nation’s small business and self-employed individuals, providing oversight of SB/SE’s $2.34 billion budget and executive leadership to a staff of over 20,000 employees responsible for service and enforcement programs for 57 million taxpayers who file personal, corporate, flow-through, employment, and excise and estate and gift tax returns. She also has oversight for two Servicewide offices that focus on IRS civil efforts in detecting and deterring tax fraud, and analyzing and identifying abusive tax transactions, tax schemes, and emerging abusive schemes.

• Recognition & Leadership

Her leadership is reflected in her progressive executive roles within the IRS, including her current position as SB/SE Commissioner, where she oversees a $2.34 billion budget and a staff of over 20,000 employees, and earlier as Deputy Chief of the IRS Independent Office of Appeals, where she worked closely with the Chief of Appeals in leading nationwide programs designed to enable Appeals employees to resolve tax controversies without litigation on a fair and impartial basis.

• Experience

Lia’s career has been built within the Internal Revenue Service across a progression of executive and leadership roles. She currently serves as SB/SE Commissioner. Previously, she served as Deputy Chief of the IRS Independent Office of Appeals, leading nationwide programs to resolve tax controversies without litigation. Prior to that, she served in dual roles as the IRS Chief of Staff and the Taxpayer First Act (TFA) office executive lead; as Chief of Staff, she worked closely with the IRS Commissioner and senior leadership team to implement strategic priorities and initiatives critical to tax administration, and as TFA office executive lead, she oversaw Servicewide implementation of TFA provisions and delivery of the TFA Report to Congress, bringing together a comprehensive taxpayer experience strategy, a holistic training strategy, and a modernized IRS organizational structure. She also previously held positions within the IRS Human Capital Office, including senior advisor to the HCO; Deputy Director, Employment, Talent and Security; and Director, Workforce Relations. She started her leadership journey in the Office of Appeals as a team manager, Collection Area Director, and Appeals Training Director.

 

Edward R. Killen, Esq., Commissioner, Tax Exempt and Government Entities | Internal Revenue Service

Edward Killen is the Commissioner of the Tax Exempt & Government Entities (TE/GE) business operating division of the Internal Revenue Service, where he is responsible for administering the tax laws governing employee retirement plans, tax-exempt organizations, tax-exempt bonds, Indian tribal governments, and federal, state, and local governments. He was selected as TE/GE Commissioner following the retirement of Commissioner Sunita Lough, having served in the role since September 30, 2022. Prior to assuming the TE/GE Deputy Commissioner role in October 2019, he served as the IRS Chief Privacy Officer, leading Privacy, Governmental Liaison and Disclosure (PGLD), where he managed a multi-faceted privacy program and ensured compliance with the Privacy Act, the Freedom of Information Act, the Federal Records Act, and Internal Revenue Code 6103. In 2025, he was promoted to the IRS’s acting chief taxpayer compliance officer, a role in which he enforces tax administration policy while overseeing taxpayer service, compliance efforts, and criminal investigations.

• Education & Credentials

Edward earned a Master’s Certificate in project management from the George Washington University School of Business. He holds a Certified Information Privacy Professional, Government (CIPP/G) credential, a Bachelor of Arts degree in political science from Valdosta State University, and a Juris Doctor degree from the University of Florida Levin College of Law. He is a member of the Florida Bar Association and the United States Tax Court.

• Recognition & Leadership

Edward was appointed a member of the Internal Revenue Service Legal Division Performance Review Board, serving in that capacity in his role as Deputy Division Commissioner, Tax Exempt and Government Entities. His leadership is further reflected in his progressive executive roles within the IRS, including TE/GE Commissioner, IRS Chief Privacy Officer, and Director of Governmental Liaison, Disclosure and Safeguards within PGLD. He began his federal service career as a Presidential Management Fellow.

• Professional Involvement

Edward is a member of the Florida Bar Association and the United States Tax Court, and he served as a member of the IRS Legal Division Performance Review Board.

• Experience

Edward’s career has been built largely within the Internal Revenue Service across a range of executive and leadership positions. He has served as Commissioner of TE/GE since September 30, 2022, succeeding Sunita Lough, and in 2025 was promoted to acting chief taxpayer compliance officer, overseeing taxpayer service, compliance efforts, and criminal investigations. He assumed the TE/GE Deputy Commissioner role in October 2019. Before that, he served as IRS Chief Privacy Officer leading PGLD, where he represented the IRS’s interests across privacy compliance, records management, information protection, disclosure, data sharing, and combating identity theft. He previously served as Director, Governmental Liaison, Disclosure and Safeguards within PGLD, providing oversight of policies and procedures regarding access to and disclosures of Federal Tax Information (FTI) under IRC Section 6103 — encompassing IRS compliance with FOIA, data exchanges with federal, state, and local government agencies, and safeguarding FTI in the custody of exchange partners. He also served as Director of the Office of Safeguards within PGLD and as Senior Advisor to the IRS Deputy Commissioner of Operations Support, providing authoritative counsel and advice. Earlier, he was on a long-term assignment to the IRS Services and Enforcement Affordable Care Act Program Office, where he played a key role in the initial scoping of the IRS’s responsibilities under the act, and before that served as Chief of the Enterprise Continuous Monitoring Branch of the W&I Security Program Management Office. He began his federal service career as a Presidential Management Fellow, with an initial appointment to the Social Security Administration Office of Hearings and Appeals. In 2003, he transferred his appointment and joined the IRS as a policy analyst within W&I Strategy and Finance, where he led the development of the W&I business plan and was part of a small group that stood up the initial Identity Theft program office within the IRS. His numerous detail assignments across the IRS include work within IRS Counsel’s office, the 2008 Economic Stimulus Program, and the Internet Strategy team.

 

Jennifer Breen, Esq., Partner | Morgan Lewis & Bockius

Jennifer Breen is a Partner at Morgan Lewis who represents domestic and multinational businesses, large partnerships, high-net-worth individuals, and family offices on tax controversy and Internal Revenue Service (IRS) administrative matters. She also counsels professional services firms, investment fund managers, and private equity firms on partnership tax issues. With decades of experience spanning government service, a “Big Four” public accounting firm, and in-house as the director of tax controversy for a large multinational corporation, Jennifer offers a rare perspective and an invaluable ability to see tax issues from multiple vantage points. Her proven skills and extensive background include all aspects of tax controversy and litigation, including managing IRS audits, filing and presenting protests in IRS Appeals, and ultimately litigating cases before the United States Tax Court and other federal courts. Drawing on her experience as an attorney with the IRS Office of Chief Counsel’s National Office, she marries substantive tax knowledge with strong relationships at the IRS and firsthand insights into navigating issues, seeking guidance, and understanding administrative processes and federal rulemaking, often seeking to resolve issues at the earliest stage possible through procedural techniques including pre-filing agreements, private letter ruling requests, requests for technical advice, and other informal methods.

• Education & Credentials

Jennifer earned her J.D. from the University of Houston Law Center in 2001 and a B.A. in Political Science and Government from the University of Texas at Austin in 1998. She is admitted to practice in the District of Columbia and Texas, and before the U.S. Court of Appeals for the First Circuit, the U.S. Court of Appeals for the Federal Circuit, the U.S. Court of Federal Claims, and the U.S. Tax Court.

• Recognition & Leadership

Jennifer is listed in Lawdragon’s 500 Leading Global Tax Lawyers for Washington, D.C., Tax, Controversy, Litigation (2025). She is recognized as Highly Regarded for Tax Controversy in the District of Columbia and as a Women in Tax Leader for Tax Controversy in the District of Columbia in International Tax Review’s World Tax Guide (2025, 2026). She is ranked for Tax: Private Client (Nationwide) in the Chambers High Net Worth Guide (2024, 2025) and for Tax in the District of Columbia in Chambers USA (2022–2025), having previously been recognized as Up-and-Coming for Tax in the District of Columbia (2020, 2021). She is recommended for Tax: US taxes: contentious in The Legal 500 US (2019, 2020) and was recommended more broadly in The Legal 500 US (2016). She is listed in The Best Lawyers in America for Tax Law in Washington, D.C. (2022–2026) and recognized by Washingtonian Magazine for Tax (2020). She was named among the Emerging Women Leaders in Private Practice by DCA Live (2019) and was a member of Law360’s Practice Group of the Year for Tax (2017). She received the IRS Special Act Award (2002–2005).

• Professional Involvement

Jennifer is a Fellow of the American College of Tax Counsel and a member of the J. Edgar Murdock Inn of Court. Within the American Bar Association’s Section of Taxation, she serves as a Council Director and previously served as Chair of Administrative Practice (2017–2018). She is a Director and Treasurer of the Washington DC Center for Public Interest Tax Law, a nonprofit tax clinic providing pro bono legal services to taxpayers across the United States, where she oversees clinic operations including regular attendance at United States Tax Court calendar calls and the delivery of pro bono legal representation to low-income taxpayers.

• Experience

Jennifer’s career spans government, public accounting, in-house, and private practice. She served as an attorney with the IRS Office of Chief Counsel’s National Office. Prior to joining Morgan Lewis, she distinguished herself as a trusted in-house advisor for Mattel, an American multinational toy manufacturing and entertainment company, where she gained a keen understanding of all aspects of tax compliance and controversy from an in-house perspective. In that capacity, she was responsible for all matters involving US federal income tax and foreign tax controversies, as well as those involving state and local corporate and business tax, sales and use tax, and escheat and unclaimed property audits, and she managed the company’s global reportable transaction compliance and compliance under the Foreign Account Tax Compliance Act. While with PwC, she represented major corporations, partnerships, S corporations, and individuals in resolving domestic and international controversy issues, counseled clients on risk management matters, and routinely advised on filing and compliance issues as well as other issues arising with accounting, audit, and internal controls. She also routinely advises clients on filing and compliance matters, voluntary disclosures, interest issues, penalty abatement actions, IRS requests and summonses, enforcement proceedings, and joint defense agreements.

 

Diana L. Erbsen, Esq., Partner | DLA Piper

Diana L. Erbsen is a Partner at DLA Piper, based in New York, with more than two decades of experience in tax controversy, representing clients in all aspects of sophisticated, challenging, and often high-stakes tax disputes. In 2014, she was appointed to the position of Deputy Assistant Attorney General for Appellate and Review for the Tax Division of the US Department of Justice (DOJ) by President Obama, and following the end of the administration on January 20, 2017, she returned to DLA Piper as a partner. Since returning, she has resumed representing public and privately held corporations, as well as partnerships, estates, and individuals, in all aspects of tax disputes, concentrating her practice on federal, state, and local tax controversies, including criminal tax matters. Informed by her experience at the DOJ and her historical perspective, she regularly counsels clients on issues relating to judicial deference to IRS guidance, including regulations, as well as on the appeal process and the intersection of criminal and civil tax enforcement.

• Education & Credentials

Diana earned an LL.M. from New York University, a J.D. from Northeastern University, and a B.A., cum laude, from Amherst College, where she held the Charles Hamilton Houston Fellowship for Scholarship & Citizenship and the John Woodruff Simpson Fellowship for the Study of Law. She is admitted to the bar in Connecticut, the District of Columbia, and New York. Her court admissions include the Supreme Court of the United States, the United States Tax Court, the United States Court of Appeals for the Federal Circuit, the United States Court of Appeals for the Second Circuit, the United States Court of Federal Claims, the United States District Court for the Southern District of New York, and the United States District Court for the Eastern District of New York. In April 2024, she was awarded a Certification of Successful Completion of Mediation Skills Training by Quinnipiac University Law School’s Center on Dispute Resolution.

• Recognition & Leadership

Diana is ranked by Chambers USA in Band 3 for Nationwide Tax: Controversy (2021–2025), having previously been ranked Band 4 (2020), and was ranked Band 1 for Nationwide Tax: Private Client, High Net Worth (2024). She is recognized by The Legal 500 United States as a Leading Partner for US Taxes: Contentious (2024–2025) and was Recommended in that category (2018–2023). In January 2017, she was recognized by IRS Chief Counsel William Wilkins with the Chief Counsel Award for her leadership and oversight of the Appellate Section of the Tax Division. She was appointed to the ABA Tax Section’s Appointments to the Tax Court Committee for a five-year term (2024–2029), serves on the American College of Tax Counsel Board of Regents as 2nd Circuit Regent, and was a member of the Law360 Tax Authority Federal 2024 Editorial Board.

• Professional Involvement

In 2020, Diana served as Chair of the IRS Advisory Council (IRSAC), which advises the IRS Commissioner on tax administration issues. Her IRSAC service, along with her roles in the leadership of the American Bar Association Tax Section and the American College of Tax Counsel (for which she currently serves as the 2nd Circuit Regent), facilitates her ability to provide up-to-the-minute guidance to clients and to help improve tax administration for the benefit of taxpayers and the IRS. She has been a member of the J. Edgar Murdock Inn of Court since 2015. She is an active speaker and panelist, having presented at venues including the NYU School of Professional Studies Tax Controversy Forum, the ABA Annual National Institute on Criminal Tax Fraud & Tax Controversy, the DC Bar Tax Conference, and the International Tax Review’s Annual Women in Tax Forum, and is frequently quoted in publications such as Tax Notes, Law360, Forbes, and The Wall Street Journal.

• Experience

Diana served as Deputy Assistant Attorney General for Appellate and Review in the Tax Division of the US Department of Justice. In her capacity as a Presidential appointee to the DOJ’s Tax Division, she oversaw its largest section, the Appellate Section (responsible for all appellate litigation, including to the Supreme Court), the Office of Review (responsible for civil settlements), and the Financial Litigation Unit (tasked with collecting judgments secured by the Trial Sections of the Tax Division). She was actively involved in the management and operations of the Civil and Criminal sections of the Tax Division and served in an ex officio capacity on the Bankruptcy Rules Advisory Committee. Earlier in her career, she served as Attorney-Adviser to the Hon. Robert Armen, Jr. of the US Tax Court. Among the specific, highly skilled areas in which she has had substantial experience are representing clients in connection with subpoenas issued by the Senate Permanent Subcommittee on Investigations; representing clients in art-related matters (including estate and gift tax, auction house guarantees, sales tax, and alleged fraudulent transfers); representing accounting firms and accountants in matters involving their ethical obligations (including pursuant to Circular 230) and their obligations under federal and state tax laws (including relating to material advisor rules, preparer penalties, and disclosure of taxpayer information); and assisting individual and institutional clients in becoming compliant with US tax laws (including with regard to undisclosed foreign financial accounts and assets).

 

Hon. Patrick J. Urda, Chief Judge | United States Tax Court

Patrick J. Urda is the Chief Judge of the United States Tax Court. Born in Indiana, he was appointed by President Trump as Judge of the United States Tax Court and sworn in on September 27, 2018, for a term ending September 26, 2033. He was elected Chief Judge for a two-year term effective June 1, 2025.

• Education & Credentials

Judge Urda received a Bachelor of Arts degree, summa cum laude, from the University of Notre Dame and a Juris Doctor from Harvard Law School.

• Recognition & Leadership

His Bachelor of Arts was conferred summa cum laude from the University of Notre Dame. His leadership is reflected in his election as Chief Judge of the United States Tax Court, effective June 1, 2025, for a two-year term.

• Professional Involvement

Judge Urda formerly served as an Adjunct Professor of Law at American University Washington College of Law.

• Experience

Prior to his appointment to the Court, Judge Urda practiced law with McDermott Will & Emery and with Maciorowski, Sackmann & Ulrich. He served as a Law Clerk to Judge Daniel A. Manion of the U.S. Court of Appeals for the Seventh Circuit and held several positions with the U.S. Department of Justice’s Tax Division, including details as Counsel to the Deputy Assistant Attorney General for Appellate and Review and to the Criminal Division’s Office of Overseas Prosecutorial Development Assistance and Training. He was appointed to the United States Tax Court and sworn in on September 27, 2018, for a term ending September 26, 2033, and was elected Chief Judge effective June 1, 2025.

 

Kenneth J. Kies, Esq., Acting Chief Counsel, Internal Revenue Service; Assistant Secretary, Tax Policy | US Department of the Treasury

Kenneth J. Kies serves as Assistant Secretary of the U.S. Department of the Treasury for Tax Policy, the senior advisor to the Secretary of the Treasury responsible for analyzing, developing, and implementing federal tax policies and programs. Nominated by President Trump in January 2025, he was confirmed by the United States Senate on June 26, 2025, by a vote of 53-45, and reports directly to Treasury Secretary Scott Bessent. He has devoted his professional career to federal tax policy and law in both the public and private sectors, having worked on virtually every aspect of the tax code. He stepped down as Managing Director of the Federal Policy Group, LLC on March 14, 2025, a position he had held since February 2002.

• Education & Credentials

Kenneth Kies attended college at Ohio University in Athens, Ohio. He began the practice of law in 1977 in Cleveland after graduating from the Ohio State University College of Law.

• Recognition & Leadership

Kenneth Kies’s leadership is reflected in his senior governmental and professional roles, including Assistant Secretary of the Treasury for Tax Policy, Chief of Staff of the Joint Committee on Taxation, and Chief Republican Tax Counsel to the House Committee on Ways and Means. In 1997, he initiated a year-long project to analyze the potential for macroeconomic estimates of major tax policy changes, resulting in the publication of the Joint Committee on Taxation Tax Modeling Project in December 1997 — at the time the most significant project of its kind and the beginning of an estimating capability that continues at the Joint Committee to this day. He served as Co-Chair, with Michael Boskin (former Chair of the Council of Economic Advisers for President George H.W. Bush), of the 1996 Ways and Means Retreat on Tax Reform under Chairman Bill Archer.

• Professional Involvement

After leaving the Joint Committee in January 1998, Kenneth Kies continued to serve at the request of Speaker Newt Gingrich and Chairman Archer in an effort to negotiate a permanent long-term solution to the solvency of the Social Security system with the Clinton Administration, in particular with Gene Sperling and Larry Summers. That effort culminated in his participation in the December 1998 White House Conference on Social Security, alongside fellow panelists Martin Feldstein (former Chair of the Council of Economic Advisers under President Ronald Reagan) and Robert Reischauer (former head of CBO); the project is recounted in a book on the history of the Social Security system entitled The People’s Pension.

• Experience

Kenneth Kies’s career spans congressional staff service, private legal practice, public accounting, and tax-policy consulting. He began the practice of law in 1977 as a tax associate with BakerHostetler in Cleveland. From 1981 until 1987, he served as Chief Republican Tax Counsel to the House Committee on Ways and Means, where he was actively involved in the development of all tax legislation, including the Economic Recovery Tax Act of 1981 and the Tax Reform Act of 1986. He subsequently served as the firmwide Chair of the Tax Practice for BakerHostetler. He served as Chief of Staff of the Joint Committee on Taxation from 1995 until 1998, overseeing development of major tax legislation including the Taxpayer Relief Act of 1997 (the first net tax cut since the 1981 Act), the Small Business Job Protection Act of 1996, and the Health Insurance Portability and Accountability Act of 1996, and helping design and negotiate the IRS Restructuring Act of 1998 with Congressman Rob Portman, Senator Ben Cardin, and Secretary of the Treasury Robert Rubin. He then served as Co-Managing Partner of the Washington National Tax Services office of PricewaterhouseCoopers LLP. From February 2002 until March 14, 2025, he was Managing Director of the Federal Policy Group, LLC, a private-sector firm providing advocacy, strategic consulting, and technical advice on tax policy matters before Congress, the Treasury Department, and the Internal Revenue Service. He was confirmed as Assistant Secretary of the Treasury for Tax Policy in June 2025.

 

Christopher M. Ferguson, Esq., Partner | Kostelanetz

Christopher M. Ferguson is a Partner at Kostelanetz LLP, based in New York City, with over two decades of experience as a litigator. He concentrates his practice on white-collar criminal defense as well as civil and criminal tax controversies and other regulatory enforcement matters and also has extensive experience handling complex civil litigation and internal investigations. Chris represents clients in both federal and state courts, as well as before governmental agencies and other regulatory bodies, including the U.S. Department of Justice, the Internal Revenue Service, the Securities and Exchange Commission, FINRA, the New York Attorney General’s Office, the U.S. Department of Labor, the New York City Department of Investigations, and the Manhattan District Attorney’s Office. He has defended clients in federal and state investigations and prosecutions involving allegations of tax fraud, securities fraud, criminal anti-trust violations (bid rigging and price fixing, including in the foreign exchange market), Bank Secrecy Act violations, mail and wire fraud, CARES Act fraud, prevailing wage fraud, theft of government services, fraud related to state and local Minority and Women Business Enterprise (MWBE) programs, and other violations of federal and state law. He also conducts internal investigations for institutional clients whose officers or employees have been suspected or accused of wrongdoing.

• Education & Credentials

Chris received his B.A., magna cum laude, from Boston College in 1994, and his J.D. from New York University School of Law in 1999. He is admitted to practice in New York State (2000), the U.S. District Court for the Southern District of New York (2001), and the U.S. District Court for the Eastern District of New York (2001).

• Recognition & Leadership

Chris is recognized in Super Lawyers for Criminal Defense: White-Collar in New York, and in Best Lawyers for Commercial Litigation and for Litigation and Controversy – Tax in New York. The Legal 500 describes him as a “key lawyer” at the Firm, and International Tax Review/World Tax describes him as “highly regarded” in the area of tax controversy. He is the former Secretary of the Criminal Law Committee of the New York City Bar Association.

• Professional Involvement

Chris is a member of the New York Council of Defense Lawyers and is the former Secretary of the Criminal Law Committee of the New York City Bar Association, having been a member of that committee since 2010. He publishes and speaks extensively in the areas of white-collar crime and civil and criminal tax controversies, with recent speaking engagements including “Tax Enforcement Trends: What’s Hot and What’s Not” (November 2024) and “Employee Retention Credit Update: Current Knowledge and Future Projections” (July 2024), and recent publications including “Defending a Pandemic Fraud Prosecution” (September 2025) and “Demystifying DeFi: Tax Compliance for Individuals Engaging In Decentralized Finance (DeFi) Transactions” (July 2025).

• Experience

In his civil practice, Chris has represented both plaintiffs and defendants in a variety of complex commercial and regulatory matters, including wage and hour class actions, Department of Labor investigations, tax shelter litigations, government procurement matters, and commercial litigations involving breach of contract, breach of fiduciary duty, fraudulent conveyances, civil fraud, civil RICO, civil forfeiture, and similar claims. Prior to joining Kostelanetz LLP, he served as a law clerk to the Honorable Jay C. Waldman of the United States District Court for the Eastern District of Pennsylvania, and was associated with the law firm of Dewey Ballantine, LLP, where he practiced in the areas of complex commercial, antitrust, and bankruptcy litigation. Among his representative matters, he has persuaded prosecutors not to charge clients and obtained non-prosecution agreements in numerous criminal tax and white-collar investigations, successfully persuaded the Office of IRS Appeals to fully abate fraud penalties assessed against a hedge fund manager, represented multiple taxpayers in tax shelter litigations in federal district courts and tax court, and conducted internal investigations for not-for-profit, quasi-governmental, and public-company clients involving suspected embezzlement, bribery, wage violations, and regulatory misconduct.

 

Megan E. Marlin, Esq., Principal | PwC

Megan E. Marlin is a Principal at PricewaterhouseCoopers LLP (PwC) in Washington, DC, specializing in compensation and benefits, with a practice focused on employment tax consulting and compliance within the firm’s Workforce Transformation group. She advises for-profit and tax-exempt employers on worker classification, fringe benefits, global mobility, remote and hybrid work arrangements, compensation arrangements, legal entity simplification, payroll transformation, post-deal integration, and federal and state payroll tax compliance. She also represents clients before the IRS and state taxing authorities to negotiate settlement agreements, manage penalty abatement requests, and lead audit and appeals defense. Prior to rejoining PwC, Megan served as Legislation Counsel for the nonpartisan Joint Committee on Taxation, where she advised Members of Congress, the House Committee on Ways and Means, and the Senate Finance Committee in the areas of employment tax, executive compensation, retirement plans, and healthcare.

• Education & Credentials

Megan graduated from the College of William & Mary in 2006 with a B.A. in International Relations. She subsequently received a J.D., cum laude, from Suffolk University Law School and an LL.M. in Taxation, specializing in Employee Benefits, from Georgetown University Law Center.

• Recognition & Leadership

Megan is the US Domestic leader for the Global Employment Tax network at PwC and is the former chair of the Employment Taxes committee of the American Bar Association. At William & Mary, she was a captain of the Division I volleyball team, a representative on the Student Athletic Advisory Council, and co-founder of the William & Mary chapter of the pre-law fraternity Phi Alpha Delta.

• Professional Involvement

Megan serves as a member of the William & Mary Washington Center Advisory Board. She is a frequent panelist for the American Bar Association, the Maryland State Bar Association, the Tax Executive Institute, and the Practicing Law Institute, and is the former chair of the ABA’s Employment Taxes committee.

• Experience

Megan is a Principal at PwC, where she advises employers on corporate restructuring and payroll transformation, global mobility, fringe benefits, equity compensation, worker classification, tax controversy, and the federal and state payroll tax compliance function. She has significant experience counseling employers on travel expense reimbursements, fringe benefits, worker classification, equity compensation, third-party payroll arrangements, U.S. employment taxes for inbound and outbound employees, and the employment tax consequences of change-of-control events, and she represents taxpayers before the IRS to negotiate settlement agreements and navigate IRS examinations and appeals. Prior to rejoining PwC, she served as Legislation Counsel with the Joint Committee on Taxation, where she assisted congressional tax-writing committees and Members of Congress with the development and analysis of legislative proposals. Earlier in her career, before joining PwC, she was an attorney specializing in tax controversy and employment taxes at a mid-sized law firm in Baltimore, Maryland, where she assisted companies with the negotiation of installment agreements and offers in compromise with the IRS and advised clients on general tax matters.

 

Daniel Graham Strickland, Esq., Partner | Holland & Knight

Daniel Graham Strickland is a Partner and tax attorney in Holland & Knight’s Washington, D.C., office. He focuses his practice in the area of federal tax controversy, representing taxpayers in all types of tax controversy matters, and also focuses on the renewable energy sector, advising clients on energy tax credits and incentives from conception to litigation. In the context of tax controversy, he guides clients through IRS audits, prepares administrative claims and protests of IRS actions, and litigates tax and tax-related cases throughout the United States, with experience covering a wide range of procedural and complex tax issues, including valuation, foreign and energy tax credits, classification of investment as debt or equity, judicial substance doctrines, and penalty defenses. In the energy sector, he advises clients on tax credits, such as investment tax credits (ITCs), production tax credits (PTCs), carbon capture, hydrogen, electric vehicle, fuels, and other energy tax credits, including through the Inflation Reduction Act (IRA) and on the impact of fuels, oil spill, and Superfund excise taxes to current and anticipated business operations.

• Education & Credentials

Daniel earned his LL.M., with distinction, from Georgetown University Law Center; his J.D., magna cum laude, from the Charleston School of Law; and his B.S. from the University of South Carolina. He is admitted to the bar in the District of Columbia. His court admissions include the U.S. Supreme Court, the U.S. Tax Court, the U.S. District Court for the District of Columbia, and the U.S. Courts of Appeals for the Second, Fourth, Fifth, Ninth, and Eleventh Circuits. While in law school, he served as the research editor for the Charleston Law Review.

• Recognition & Leadership

Daniel was named a John S. Nolan Fellow by the American Bar Association (ABA) Section of Taxation for 2024-2025. He is recognized in The Best Lawyers in America guide as “Ones to Watch” for Washington, D.C. Litigation and Controversy, Tax (2021-2025) and for Washington, D.C. Energy Law and Tax Law (2024, 2025). His leadership roles include serving as Section Chair of the Federal Bar Association’s Section on Taxation (2022-2023) and as Vice Chair of the ABA Section of Taxation’s Energy & Environmental Taxes Committee (2022-Present).

• Professional Involvement

Daniel is active in several professional organizations. Within the Federal Bar Association (FBA) Section on Taxation, he served as Section Chair (2022-2023), is Past Co-Chair of the Tax Practice and Procedure Committee and has been a Steering Committee Member since 2017. Within the American Bar Association (ABA) Section of Taxation, he serves as Vice Chair of the Energy & Environmental Taxes Committee (2022-Present) and previously served as Technology Liaison to the Court Practice and Procedure Committee (2021-2022). He is also a member of the D.C. Bar Association’s Taxation Community and is Past Chair of its New Tax Practitioner Subcommittee. He represents clients in the traditional and renewable energy sectors in legislative and regulatory efforts, including in obtaining public and private guidance from the U.S. Department of the Treasury and the IRS.

• Experience

Prior to joining Holland & Knight, Daniel was an attorney for a global law firm in its Washington, D.C., office. Previously, he served as a law clerk at the U.S. Tax Court for the Honorable Albert G. Lauber, the Honorable Elizabeth Crewson Paris, and the Honorable Michael B. Thornton. He represents clients in tax controversy matters at the administrative, trial court, and appellate levels, guiding them through IRS audits, preparing administrative claims and protests of IRS actions, and litigating tax and tax-related cases throughout the United States. In the energy sector, his work spans advising clients on a broad range of energy tax credits and incentives and on the impact of fuels, oil spill, and Superfund excise taxes, as well as representing clients in legislative and regulatory efforts before the U.S. Department of the Treasury and the IRS.

 

Leila D. Carney, Esq., Member | Caplin & Drysdale, Chartered

Leila D. Carney is a Member at Caplin & Drysdale, based in Washington, D.C., and a seasoned tax lawyer with a focus on resolving disputes with the IRS. Her core practice involves providing a surgical defense to IRS audits, assessments, and penalties, including litigation in the Court of Appeals for the D.C. Circuit, the U.S. Tax Court, Federal District Court, and the D.C. Circuit Court against the IRS and the Department of Justice. She is adept at handling multifaceted issues involving global business and investing structures for individuals, corporate clients, and complex trusts, and has handled sensitive IRS exams, administrative appeals, criminal matters, Circular 230 disciplinary proceedings, represented subpoenaed witnesses, and submitted ruling requests and comment letters on proposed regulations. She has practiced in the Tax Disputes & Tax Litigation Group since first joining Caplin & Drysdale’s Washington, D.C. office in 2004, and also provides her tax, litigation, and federal law expertise to the firm’s Complex Litigation, Criminal Tax & White Collar Defense, Private Client, and Political Law Practices.

• Education & Credentials

Leila earned her J.D. from the University of Virginia School of Law in 2004 and her B.A. from The College of William & Mary in 2001. She is admitted to practice in the District of Columbia and Virginia, and before the U.S. Court of Appeals for the D.C. Circuit, the U.S. Tax Court, the U.S. District Court for the Eastern District of Virginia, and the D.C. Circuit Court.

• Recognition & Leadership

Leila serves on the Tax Notes Federal Advisory Board, shaping content for Tax Analysts, a leading publisher on tax law and policy. She was elected a Member of Caplin & Drysdale in October 2023. Her thought leadership is reflected in her frequent commentary in outlets including Bloomberg Law, Tax Notes, Law360, Financial Planning, Accounting Today, MarketWatch, The Hill, and others, on matters such as Moore v. United States, the Chevron decision, the Corporate Transparency Act, and regulatory authority in tax legislation.

• Professional Involvement

Leila is a Member of the Tax Notes Federal Advisory Board, the American Bar Association’s Section of Taxation, and the District of Columbia Bar. Within the ABA Tax Section, she has led the Administrative Practice Committee on the IRS LB&I Puerto Rico Campaign (August 2024). She is an active speaker and author, with engagements including the NYU Tax Controversy Forum (exploring the Employee Retention Credit, June 2026), and publications appearing in the Pittsburgh Tax Review, Practical Tax Strategies (Thomson Reuters), Procedurally Taxing, and the firm’s Tax and International Tax Alerts on topics such as the Corporate Transparency Act, Puerto Rico residency audits, conservation easements, and refund claims.

• Experience

Throughout her career, Leila has zealously won an appeal to the D.C. Circuit Court of Appeals, converting a Tax Court loss into a win; litigated cases involving foreign-source income, captive insurance, conservation easements, and IRS third-party summonses; defended Puerto Rico residency and sourcing in IRS campaign audits; navigated the Congressional Joint Committee on Taxation large tax refund review process; defended a gift tax return examination involving a high-net-worth trust structure; sought full abatement of civil penalties related to foreign trust reporting, return preparer penalties, and appraiser penalties; sought full allowance of large deductions in IRS “hobby loss,” “cost segregation,” and “real estate professional” examinations, and a refund of Net Investment Income Tax (NIIT); assisted victims of criminal tax return preparers in providing testimony and correcting returns; coordinated reinstatement of an inadvertent S-corp termination; sought “9100” relief for missed “check the box” elections; and advised on presidential ballot access law and procedure. She has represented clients in sensitive audits with a risk of allegations of tax fraud or securities fraud, assisted clients responding to subpoenas for civil and criminal proceedings and those under investigation, and protested civil penalties including those specific to foreign bank accounts, trusts, gifts, preparers, promoters, and appraisers. She has represented clients on voluntary disclosures and collection matters such as offers-in-compromise, lien releases, installment agreements, decertifying passports, and innocent spouse petitions; assisted with state tax aspects such as California Franchise Tax Board exams, resolution programs, and collection activities; and is experienced in obtaining and defending tax-exempt status for public and private charities as well as trade associations. She has also advised clients on creating business practices that comply with changing regulatory regimes, including those governing taxpayer consent to disclosure of tax return information, foreign bank account reporting (FBAR), and nonqualified deferred compensation plans, and has assisted clients in submitting comments on proposed regulations.

 

Eric Hylton, National Director | alliant

Eric Hylton is a National Director (National Director of Compliance) at alliantgroup and the former IRS Commissioner of the Small Business/Self-Employed (SB/SE) Division, a position to which he was appointed in September 2019. He spent approximately 30 years at the Internal Revenue Service, where he held several prominent positions, including serving as Deputy Chief of the Criminal Investigation (CI) Division and as CI’s head of International Operations.
As National Director at alliantgroup, he employs his years of experience at the IRS to assist the firm’s clients, serving as an ambassador for U.S. small and medium-sized businesses (SMBs) and helping others become tax compliant.

• Education & Credentials

Eric attended Morehouse College.

• Recognition & Leadership

Eric is the former chair of the Organization for Economic Cooperation and Development (OECD) Task Force for Tax Crimes and Other Financial Crimes. As Chair, he led a multilateral commission of 40 international criminal tax organizations to develop methodologies and typologies on emerging global criminal tax and financial crimes threats — work that resulted in significant legislative changes, billions in revenue, and the establishment of joint international investigative teams. His leadership is further reflected in his senior IRS roles, including Commissioner of the SB/SE Division, Deputy Chief of the Criminal Investigation Division, and head of CI’s International Operations.

• Professional Involvement

In his role at alliantgroup, Eric serves as an ambassador for U.S. small and medium-sized businesses and assists clients in becoming tax compliant. He also served as the former chair of the OECD Task Force for Tax Crimes and Other Financial Crimes, and has served as Director of Investigations for Zerbe, Miller, Fingeret, Frank & Jadav LP (ZMF Law), advising clients on criminal tax investigations, tax controversy matters, internal investigations, cryptocurrency, and whistleblower claims.

• Experience

Eric’s career has spanned approximately 30 years of senior leadership at the IRS, subsequent private-sector roles, and his current position at alliantgroup. Within the IRS, he held positions including Commissioner of the Small Business/Self-Employed Division (appointed September 2019), Deputy Chief of the Criminal Investigation Division, Executive Director / head of CI’s International Operations, and Director of CI’s Narcotics and Counterterrorism Office. Among his select career accomplishments, in civil investigation he directed the IRS’s Audit and Collection tax operations with a $2.2 billion yearly budget and 20,000 nationwide employees, with oversight for 800,000 audits and billions of tax dollars assessed and collected. In criminal investigation, he oversaw the sixth-largest U.S. federal law enforcement agency, with a worldwide staff of approximately 3,000 employees that resulted in over 6,000 investigations recommended for prosecution, leading to thousands of individuals convicted and sentenced. In fraud investigation, he revolutionized the IRS’s National Fraud Program — establishing emerging threat teams, revamping organizational structure, revising metrics, and streamlining processes that resulted in multimillion-dollar fraud schemes being referred for criminal purposes. In the area of international partnership, he led a multilateral commission of 40 international criminal tax organizations to establish global methodologies on emerging financial fraud threats, resulting in significant legislative changes, billions in revenue, and the establishment of joint international investigative teams. He later served as Director of Investigations for ZMF Law before his role as National Director at alliantgroup.

 

Darren John Guillot, National Director | alliant

Darren Guillot is a National Director at alliantgroup, based in Houston, and a former IRS Commissioner of the Small Business/Self-Employed (SBSE) Division. As an alliantgroup trusted tax advisor and consultant, Mr. Guillot assists small and medium-sized businesses in navigating America’s tax system to secure incentives and credits that stimulate innovation and improve products and services. He also serves them as an expert resource resolving complex compliance and appellate controversies.

• Education & Credentials

Mr. Guillot holds a bachelor’s degree from the University of Holy Cross. He is a Fellow of the Loyola University Institute of Politics and was awarded the Certificate in Public Leadership by the Brookings Institution.

• Recognition & Leadership

During his tenure as Commissioner, SBSE (2021–2022), Mr. Guillot led the IRS’s groundbreaking, successful effort using authenticated voice robotics, eliminating phone hold times for over 14 million taxpayers in less than two years. He also led the creation and oversight of the IRS’s Fraud Enforcement Office, providing support and coordination for all IRS efforts in detecting and deterring tax fraud—including leading the most expansive and innovative use of data and systems analytics to address virtual currency by the civil functions of the IRS. Earlier, he created, implemented, and provided top leadership for the Appeals Judicial Approach & Culture Project (2011–2013), whose resulting policies and procedures remain in use today.

• Professional Involvement

As an alliantgroup contributor, Mr. Guillot participates in the firm’s thinktank+ webinar series, which features former IRS commissioners, members of Congress, and leading tax experts addressing day-to-day tax obstacles.

• Experience

Mr. Guillot recently retired from the IRS after 36 years with the agency. His roles included serving as Commissioner of the IRS’s Small Business/Self-Employed Division, overseeing all IRS domestic and international Collection Operations and its Operations Support functions. His extensive enforcement background at the IRS was balanced by 14 years of experience in the IRS’s Independent Office of Appeals, culminating in his creation, implementation, and top leadership of the Appeals Judicial Approach & Culture Project (2011–2013). He began his IRS career as a revenue officer. Today, at alliantgroup, he advises small and medium-sized businesses on securing tax incentives and credits and serves as an expert resource resolving complex compliance and appellate controversies.

 

Elizabeth P. Askey, Esq., Of Counsel | Skadden, Arps, Slate, Meagher & Flom

Liz Askey is Of Counsel in the Tax Controversy and Litigation practice at Skadden, Arps, Slate, Meagher & Flom LLP, based in the firm’s Washington, D.C. office. She has more than three decades of experience advising on tax controversy matters, including examinations, appeals, alternative dispute resolution, and litigation. She also has extensive experience in controversy mitigation strategies, including private letter rulings, closing agreements, prefiling agreements, the Industry Issue Resolution program, and regulatory and legislative tax policy advocacy.

• Education & Credentials

Ms. Askey earned her J.D., cum laude, from Harvard Law School (1990) and her A.B., magna cum laude, from Bryn Mawr College (1987). She is admitted to practice in New York, the District of Columbia, and Pennsylvania, and before the U.S. Tax Court, the U.S. Court of Federal Claims, and the U.S. Court of Appeals for the Federal Circuit.

• Recognition & Leadership

Ms. Askey is a Fellow of the American College of Tax Counsel. During her government service, she rose to several high-level IRS positions, including Chief of the IRS Independent Office of Appeals, where she set strategy and oversaw the operations of nearly 1,800 Appeals employees, as well as Deputy Chief of Appeals and Deputy Division Counsel (International) for the IRS Office of Chief Counsel’s Large Business and International (LB&I) Division.

• Professional Involvement

Ms. Askey is a Fellow of the American College of Tax Counsel and has held leadership positions with the taxation sections of the American Bar Association, the Federal Bar Association, and the District of Columbia Bar. She is an active author and speaker on IRS Appeals and tax controversy developments, with recent publications addressing IRS Appeals challenges for 2026, expedited IRS dispute-resolution processes, post-Appeals mediation guidance, and IRS procedural reforms for early resolution of business controversies, and recent speaking engagements including the TEI-SJSU High Tech Tax Institute, the Procopio International Tax Institute, and the TEI Annual Conference.

• Experience

Ms. Askey joined Skadden after serving in several high-level positions at the IRS, including most recently as Chief of the Independent Office of Appeals, where she set strategy and oversaw the operations of nearly 1,800 Appeals employees and programs designed to resolve tax controversies between taxpayers and the IRS without litigation. She previously served as Deputy Chief of Appeals and, before that, as Deputy Division Counsel (International) for the IRS Office of Chief Counsel’s LB&I Division, where she directed the work of approximately 350 attorneys and paralegals responsible for litigating LB&I cases and providing advice to exam teams and Appeals. Earlier in her career, she served as an attorney-advisor and associate tax legislative counsel in the Office of Tax Policy at the Department of the Treasury. In addition to her government roles, Ms. Askey spent over two decades as a tax controversy and policy practitioner at several law and accounting firms and in private industry, where she represented clients in litigation, examinations, and at Appeals, and advised on regulatory and legislative tax policy matters before Treasury, the IRS, and congressional staff, with an emphasis on tax accounting, research and development credits and expenses, and energy tax.

 

Tomika L. Bullet, CPA, Principal | Tax Controversy, Windham Brannon

Tomika L. Bullet is the Principal of Tax Controversy at Windham Brannon, based in the firm’s Atlanta, Georgia office. She has over 20 years of experience in the tax and audit industry. Tomika spent almost 15 years at the Internal Revenue Service (IRS) in the Small Business/Self-Employed (SB/SE) division, where she specialized in the management of partnership, corporate, and high-net-worth individual examinations.

• Education & Credentials

Tomika received her Master of Taxation from Georgia State University and her Bachelor of Science in Accounting from Tuskegee University. She is a licensed Certified Public Accountant in Georgia and Illinois.

• Recognition & Leadership

She serves as Principal of Tax Controversy at Windham Brannon and previously served as Vice President of Operations for the National Association of Black Accountants.

• Professional Involvement

Tomika is a member of the American Institute of Certified Public Accountants, where she serves on the IRS Advocacy & Relations Committee, and a member of the Georgia Society of Certified Public Accountants. She previously served as Vice President of Operations for the National Association of Black Accountants. She is an active author and presenter, with thought-leadership pieces on COVID-19 penalty refunds, IRS conservation easement settlement offers, Form 5500 penalties, and IRS refund-fraud notices, and presentations including “Top Considerations in Filing for ERC and Preparing for an ERC Audit” (Insights 2023), an ERC session for the American Bar Association Collections & Bankruptcy Group Virtual Tax Meeting (2023), “Top IRS Audit Triggers” (Insights 2022), and “What to do When Ghosting the IRS Comes to an End” (Georgia Federal Tax Conference 2022). She is passionate about volunteering and gives her time to several not-for-profit organizations.

• Experience

Tomika has over 20 years of experience in the tax and audit industry. As Principal of Tax Controversy at Windham Brannon, her work spans tax controversy, the Employee Retention Credit, and business tax, including industry focuses such as construction and manufacturing and distribution. She spent almost 15 years at the IRS in the Small Business/Self-Employed division, where she specialized in the management of partnership, corporate, and high-net-worth individual examinations. Before joining the IRS, Tomika was an Internal Audit Project Lead with BellSouth, where she conducted Sarbanes-Oxley testing and other business reviews for internal operations. She began her career with PricewaterhouseCoopers, LLP as an Audit Associate in the financial statement group.

 

Yvonne R. Cort, Esq., Partner | Capell Barnett Matalon & Schoenfeld

Yvonne R. Cort is a Partner at Capell Barnett Matalon & Schoenfeld LLP, where she focuses her practice on resolving federal and New York State tax controversies. For over twenty years, Yvonne has assisted individuals and businesses with IRS and NYS tax matters, including New York State and New York City residency audits, IRS and NYS audits and appeals, unfiled returns, income tax, sales tax, withholding tax, responsible person assessments, liens and levies, tax warrants, innocent spouse relief, voluntary disclosure, installment agreements, and offers in compromise.

• Education & Credentials

Yvonne received her B.A., magna cum laude, from the University of Rochester and her J.D. from the University of Pennsylvania Carey Law School. She is admitted to the Bar in New York and Pennsylvania, and admitted to practice before the United States Tax Court.

• Recognition & Leadership

Yvonne has been selected for over ten years to New York Metro Super Lawyers (2015–2026), a designation given to only 5% of the lawyers in the state. She has been honored as one of the Top 50 Women in Business (Long Island Business News, 2020), one of the Power Women in Business (Schneps – Long Island Press, 2018), and a Premier Business Woman of Long Island (Long Island Herald, 2024), and was honored with a Woman of Achievement Award (June 2026). She has served as a Member-at-Large of the Executive Committee of the NYS Bar Association Tax Section, where she has contributed to policy papers, and has held leadership positions including Chair of the IRS Downstate New York Practitioner Liaison Group; Chair of the Business Law, Tax and Accounting Committee of the Nassau County Bar Association; Co-Chair of the Attorneys and Accountants Joint Committee of the NYS Society of CPAs, Nassau Chapter; and member of the Executive Committee of the Accounting and Tax Symposium.

• Professional Involvement

Yvonne is a regular speaker for many professional groups and a prolific author whose articles on tax topics have been featured in accounting and legal publications such as the Journal of Multistate Taxation and Incentives and the Tax Stringer, published by the New York State Society of CPAs. Her recent and recurring speaking engagements include the NYU Tax Controversy Forum (multiple years, with 2026 topics including “Seeking an Independent Review – The Current State of IRS Appeals and ADR” and family office tax planning), Nassau County Bar Association programs on NYS and NYC residency issues, IRS liens, levies, enforcement procedures and tax resolution strategies, and the annual Accounting and Tax Symposium and NYSSCPA Nassau/Suffolk Chapter tax conferences. Her writing covers NYS and NYC residency and domicile, responsible person assessments, innocent spouse relief, installment agreements, telecommuting and residency, and IRS administrative appeals. She has been interviewed by various media outlets and quoted in leading publications including Bloomberg BNA, Crain’s New York Business, and Newsday.

• Experience

For over twenty years, Yvonne has represented individuals and businesses in federal and New York State tax controversy and compliance matters. Her work includes New York State and New York City residency audits, IRS and NYS audits and appeals, unfiled returns, income tax, sales tax, and withholding tax matters, responsible person assessments, liens and levies, tax warrants, innocent spouse relief, voluntary disclosure, installment agreements, and offers in compromise. She practices from the firm’s Long Island (Syosset) and New York City offices.

 

Daniel Nettles, Esq., Director | Andersen Tax

Dan Nettles is a director in Andersen’s US National Tax practice, based in Orange County, California, specializing in federal tax controversy and dispute resolution. He has eight years of experience representing corporate and individual taxpayers in examinations, administrative appeals, and complex disputes involving a broad range of federal tax matters. At Andersen, Dan represents clients in complex tax controversies, including examinations, appeals, and litigation readiness, with experience spanning industries such as technology, private equity, life sciences, manufacturing, and professional services.

• Education & Credentials

Dan earned his BA in English from the University of Oregon and his JD, with a tax focus, from UC College of Law – San Francisco.

• Professional Involvement

Dan is a frequent speaker on federal tax controversy topics, including presentations for programs hosted by the Tax Executives Institute (TEI).

• Experience

Dan began his career with the IRS Office of Chief Counsel (SB/SE), where he supported examination teams and represented the government in litigation before the U.S. Tax Court, gaining extensive experience handling controversy matters involving income tax, penalties, and procedural issues affecting both businesses and individuals. Following his government service, he joined the tax controversy practice at DLA Piper LLP (US), where he represented clients across multiple industries in high-stakes federal tax disputes, including audits, appeals proceedings, and litigation, and provided guidance on controversy strategy, risk assessment, and resolution options. At Andersen, he represents clients in complex tax controversies, including examinations, appeals, and litigation readiness, across industries including technology, private equity, life sciences, manufacturing, and professional services.

 

Daniel Mayo, Esq., Partner | WithumSmith+Brown, PC

Dan Mayo is a Partner with Withum, based in the firm’s Red Bank, New Jersey office, with over 25 years of professional tax experience in federal, international, and financial products taxation. As the Lead for Withum’s National Tax Services practice, he helps businesses structure their affairs and plan transactions to minimize federal income taxes. He is experienced in mergers and acquisitions, capital markets transactions, and cross-border transactions, and he represents individuals and businesses in tax controversies with the IRS. Dan also serves as an expert witness in litigation involving tax issues and is a recognized expert in the areas of Qualified Small Business Stock (QSBS) and the Employee Retention Credit (ERC), co-leading Withum’s ERC Group.

• Education & Credentials

Dan earned his LL.M. in Tax from New York University School of Law, his Juris Doctor, cum laude, from Seton Hall University School of Law, and his B.S. in Accounting from Rutgers College.

• Recognition & Leadership

Dan is a recognized expert in the areas of Qualified Small Business Stock (QSBS) and the Employee Retention Credit (ERC), and he co-leads Withum’s ERC Group. He is a thought leader within the Firm and an adjunct tax professor at Georgetown University Law Center and previously served as Chair of the Banking & Savings Institutions Tax Committee of the American Bar Association’s Tax Section.

• Professional Involvement

Dan is an adjunct tax professor at Georgetown University Law Center and an approved arbitrator for FINRA and previously served as Chair of the Banking & Savings Institutions Tax Committee of the American Bar Association’s Tax Section. He is a frequent speaker on webinars and at external tax conferences and writes for tax publications including the Daily Tax Report and Tax Notes Today. His recent authored insights address QSBS eligibility and Treasury scrutiny of QSBS “stacking” strategies, the IRS appeal of Kwong v. United States and COVID-era interest and penalty relief, the Fifth Circuit’s self-employment tax decision in Sirius Solutions v. Commissioner, Section 280G in M&A transactions, and the QSBS provisions of the 2025 One Big Beautiful Bill Act.

• Experience

Dan has over 25 years of professional tax experience in federal, international, and financial products taxation. As Lead of Withum’s National Tax Services practice, he helps businesses structure their affairs and plan transactions to minimize federal income taxes, with experience in mergers and acquisitions, capital markets transactions, and cross-border transactions. He represents individuals and businesses in tax controversies with the IRS, co-leads the firm’s ERC Group, and serves as an expert witness in litigation involving tax issues, with particular depth in Qualified Small Business Stock and the Employee Retention Credit. His industry focus includes financial services, professional services, real estate, and technology and emerging growth.

 

G. Michelle Ferreira, Esq., Managing Shareholder | Greenberg Traurig

Michelle Ferreira is Executive Vice President, Co-Chair of the Global Tax Practice, and Managing Shareholder of Greenberg Traurig’s Silicon Valley office, practicing from the firm’s San Francisco and Silicon Valley offices. She advises individuals, partnerships, estates, and corporations in complex tax disputes with the Internal Revenue Service and state and local tax authorities, including the California Franchise Tax Board, the California Department of Tax and Fee Administration, the Employment Development Department, and county assessment appeals boards. Drawing on her prior experience as a tax litigator with the IRS, Michelle brings a distinctive and strategic perspective to sensitive and high-stakes tax and penalty matters, representing clients at every stage of a tax controversy—audits, collections, appeals, and litigation—before the IRS and state and local taxing authorities. She has 23 reported decisions in the U.S. Tax Court addressing a wide range of sophisticated tax issues, and is a member of the firm’s Tariff Task Force.

• Education & Credentials

Michelle earned her J.D. from Santa Clara University School of Law and her B.S. from the University of California at Davis. She is admitted to practice in California, and before the Supreme Court of California, the U.S. District Courts for the Northern and Central Districts of California, and the U.S. Tax Court. She speaks conversational Spanish.

• Recognition & Leadership

Michelle is a Fellow of the American College of Tax Counsel. She has been listed in The Best Lawyers in America for Litigation and Controversy–Tax and Tax Law (2011–2026), including “Lawyer of the Year” for Tax Law in San Francisco (2026) and for Litigation and Controversy–Tax in San Francisco (2023). She has been recognized by the International Tax Review as a World Tax Leader–Americas, “Highly Regarded” (2023, 2025, 2026) and a Women in Tax Leader (2025–2026); listed in the Chambers USA Guide (2017–2026); named among Lawdragon’s “500 Leading Global Tax Lawyers” (2025); and recognized by The Legal 500 United States for Tax–U.S. Taxes: Contentious and Tax Controversy across multiple years. She was shortlisted for Euromoney’s “Women in Business Awards – Tax Dispute Resolution Lawyer of the Year” (2024), won the Collaborative Leadership Award at the Women, Influence & Power in Law Awards (Corporate Counsel, 2023), repeatedly earned “Best in Tax Dispute Resolution” recognition from Euromoney/IFLR, received the V. Judson Klein Award from the State Bar of California, Taxation Section (2012), and a Performance Award from the IRS Small Business/Self-Employed Division (2001). She has been listed in Northern California Super Lawyers (2008–2025).

• Professional Involvement

Michelle is a member of the American Bar Association, Taxation Section, and the San Francisco Tax Club. Within the California State Bar, Taxation Section (2006–present), she served as Chair (2009–2010) and as a member of the Executive Committee (2006–2010). She is an Adjunct Professor at Golden Gate University School of Tax.

• Experience

Michelle’s noteworthy experience includes serving as a Trial Attorney with the Internal Revenue Service, Office of Chief Counsel, from 1995 to 2003. In private practice, she represents clients at every stage of a tax controversy—audits, collections, appeals, and litigation—before the IRS and state and local taxing authorities. Her concentrations include IEEPA tariff recovery; tax compliance and advisory matters; civil tax disputes including audits, appeals, and collections; offshore penalty and foreign income tax controversies; complex tax litigation; California Franchise Tax Board and Department of Tax and Fee Administration audits, protests, and Office of Tax Appeals litigation; California state residency audits; estate and gift tax disputes; valuation controversies; criminal tax investigations and litigation; federal and state tax penalties; tax shelter audits, investigations, and litigation; and tax shelter promoter audits. Her 23 reported U.S. Tax Court decisions address issues including split-dollar life insurance, unreported income, family limited partnerships, gift tax and valuation disputes, civil and criminal tax fraud, penalty assessments, statute of limitations defenses, discounts for lack of control and marketability, tax shelters, hobby losses, complex real estate and structured transactions, Bipartisan Budget Act of 2015 partnership audits, microcaptive insurance companies, conservation easements, Employee Retention Credit disputes, and substantiation of business expenses.

 

Michelle F. Schwerin, Esq., CPA, Shareholder | Neill Schwerin Boxerman, PC

Michelle F. Schwerin is a Shareholder at Neill Schwerin Boxerman, P.C. in St. Louis. As an attorney-CPA, Michelle represents clients in civil tax examinations, appeals, and litigation, as well as criminal tax investigations and defense. She is also an advocate in the field of white-collar criminal defense, counseling individuals and businesses involved in financial investigations or charges of various white-collar crimes.

• Education & Credentials

Michelle earned her J.D., with honors, from Washington University (2010) and her B.S.M. in Finance and Accounting, with honors, from Tulane University (2006). She is admitted to practice in Missouri and Illinois, and before the U.S. District Courts for the Eastern District of Missouri and the District of Colorado and the U.S. Tax Court. She is also a Certified Public Accountant in Missouri.

• Recognition & Leadership

Michelle was named “Lawyer of the Year” for Litigation and Controversy–Tax in St. Louis by Best Lawyers (2023) and has been listed in The Best Lawyers in America for Criminal Defense: White-Collar, Tax Law, and Litigation and Controversy–Tax in St. Louis (2017–present). She has appeared on the Missouri and Kansas Rising Stars list of Super Lawyers (2018–present) and The POWER List–Tax in Missouri Lawyers Weekly (2021 and 2022). Her other honors include the J Associates Emerging Leader Award from the St. Louis Jewish Community Center (2021), the Outstanding Young Professional Award from the Missouri Society of Certified Public Accountants (2017), the John C. Shepherd Professional Award from the Bar Association of Metropolitan St. Louis (2016–2017), the Nolan Fellowship from the American Bar Association Section of Taxation (2014–2015), and membership in the Missouri Bar Leadership Academy (2013–2014).

• Professional Involvement

On a national level, Michelle serves as Vice-Chair of the Court Practice and Procedure Committee within the American Bar Association Section of Taxation, focusing on tax litigation, and is the immediate past-Chair of the Standards of Tax Practice Committee, responsible for educating and advocating on behalf of the tax bar with respect to ethical standards, Circular 230, and the standards of conduct imposed on practitioners by various penalty provisions; she previously served as Co-Chair of the Civil Penalties Updates and Criminal Penalties Updates Subcommittees of the Civil and Criminal Tax Penalties Committee. She previously served on the Board of Directors of the Missouri Society of CPAs (2021–2024) and as Chair of its St. Louis Chapter (2020–2021), and has held leadership roles with the Bar Association of Metropolitan St. Louis; she is also a member of the Federal Bar Association, the Missouri Bar, and the Women in White Collar Defense Association. Michelle is an adjunct professor of law in Washington University Law School’s Tax LL.M. program, where she teaches Accounting for Tax Lawyers and Corporate and White Collar Crime, and is a former adjunct professor at Webster University’s George Herbert Walker School of Business & Technology. She is a prolific speaker before the ABA Tax Section, the NYU Tax Controversy Forum, the UCLA Tax Controversy Conference, and the National Institute on Criminal Tax Fraud, among others, and an author whose work has appeared in the St. Louis Bar Journal, Criminal Justice, The Asset, and St. Louis Lawyer Magazine, on topics including voluntary disclosure, payroll tax fraud, virtual currency, and identity theft. In the community, she served as Vice Chair of the Board of Police Commissioners for the St. Louis County Police Department (2019–2024) and on the board of the St. Louis Economic Development Partnership (2024–2025), was appointed to the Gateway Regional Law Enforcement Training Center Commission, and holds board positions at the Henry and Gladys Crown Center for Senior Living and the St. Louis Jewish Community Center.

• Experience

Michelle represents individuals and businesses across civil tax examinations, appeals, and litigation, criminal tax investigations and defense, white-collar criminal matters, and digital currency matters. Her representative civil tax results include persuading the IRS Office of Appeals to completely concede hundreds of thousands of dollars in penalties asserted under 26 U.S.C. § 6694(b) against a national accounting firm; persuading the IRS that a medical professional met the material participation requirements under § 469; obtaining abatement of over $200,000 in penalties under §§ 6721 and 6722 related to the Affordable Care Act; and persuading the IRS Office of Appeals to concede over $10 million in proposed adjustments in a § 183 hobby loss matter involving a thoroughbred horse breeding and racing business. Her representative criminal tax results include negotiating probation rather than the two-year prison sentence sought by the DOJ for a small business owner in a multi-year tax evasion investigation; resolving a multi-year non-filer prosecution with a probation sentence; and securing a plea to a lesser charge with no incarceration after extensive trial preparation. In white-collar matters, she has guided a former campaign manager through highly publicized investigations, persuaded the SEC not to pursue enforcement against a corporate executive in an insider trading and earnings management investigation, and resolved a federal opioid-prescription investigation of a physician without criminal charges. In digital currency matters, she has handled an IRS audit of a digital currency trader resulting in no change, advised a bitcoin mining machine retailer on securities reporting obligations, and advised a trade association on tax matters related to digital assets.

 

Kathy A. Enstrom, MBA, EA, COO and Director of Investigations | Moore Tax Law Group

Kathy Enstrom is the Chief Operating Officer and Director of Investigations for the Moore Tax Law Group, based in Chicago, and a former Executive within Internal Revenue Service Criminal Investigation (IRS CI). Having spent nearly 28 years in federal law enforcement, Ms. Enstrom has expertise in financial crimes, specifically income and employment tax evasion, money laundering, Bank Secrecy Act violations, government assistance fraud, and bank fraud.

• Education & Credentials

Ms. Enstrom holds a Bachelor of Business Administration in Accounting from Mount Mercy University (Cedar Rapids, IA) and a Master of Business Administration from Cardinal Stritch University (Milwaukee, WI). She is a Certified Fraud Examiner through the Association of Certified Fraud Examiners and an Enrolled Agent authorized to represent taxpayers before the Internal Revenue Service.

• Recognition & Leadership

Ms. Enstrom rose to an executive position within IRS CI, where her last assignment was to serve as Executive Director of Field Operations–Northern Area, overseeing one-third of the United States, including offices headquartered in Chicago, Detroit, Cincinnati, Philadelphia, Newark, Boston, and New
York City. Previously, she was the Executive Special Agent in Charge for the Chicago Field Office and the Executive Director for CI’s Operations, Policy and Support.

• Professional Involvement

Ms. Enstrom is a sought-after speaker and panelist on financial crimes, tax enforcement, and forensic accounting. Her recent engagements include panels at the NYU Tax Controversy Forum (multiple years), the IRS Tax Representation Conference, the Hawaii Tax Institute, the UCLA Tax Controversy Institute, the ABA National Institute on Criminal Tax Fraud, the West Coast Anti-Money Laundering Conference, and the Cambridge International Symposium on Economic Crime, as well as CPA society conferences in Illinois and Wisconsin. She has spoken on topics including trends in financial crimes, employee retention credit enforcement, conducting financial investigations from both sides of a case, the role of the forensic accountant, and ethics, and has appeared on several podcasts addressing investigations and tax-season scams.

• Experience

Ms. Enstrom spent nearly 28 years in federal law enforcement. She began her IRS career in 1995 as an intern with IRS CI in Cedar Rapids, Iowa, and the following year was sworn in as a Special Agent in Chicago, Illinois, subsequently moving through various investigative and management roles in Chicago, New York City, Washington, D.C., Los Angeles, Milwaukee, Cincinnati, and Ottawa, Canada. As Executive Director for CI’s Operations, Policy and Support, she oversaw all CI policy and Internal Revenue Manual updates as well as the Financial Crimes Section, National Forensic Lab, Special Investigative Techniques Section, Warrants & Forfeitures Section, Treasury Liaison, TEOAF Liaison, and FinCEN Liaison. Her federal law enforcement career concluded with her role as Chicago’s Special Agent in Charge of the Federal Deposit Insurance Corporation, Office of Inspector General, from July 2021 to March 2023, where she conducted investigations involving bank fraud and oversaw agents covering six Midwestern states—Illinois, Wisconsin, Indiana, Michigan, Ohio, and Kentucky. She now applies this experience to financial crimes and tax investigations at the Moore Tax Law Group.

 

Beverly Winstead, Esq., Principal | Law Office of Beverly Winstead

Beverly Winstead is the founder and a tax attorney at the Law Offices of Beverly Winstead, LLC, a tax resolution law firm with offices in Baltimore and Laurel, Maryland. Being an attorney has given Beverly the opportunity to change many of her clients’ lives for the better by solving their personal and business tax issues. From negotiating settlements with the Internal Revenue Service (IRS) that are comfortable for clients to getting the IRS to release a lien or levy, the favorite part of her tax practice has always been the peace she gives clients when she tells them that their debt has been significantly reduced or their tax issues have been resolved. The Law Offices of Beverly Winstead, LLC is affiliated with the accounting firm Winstead Tax Group, LLC.

• Education & Credentials

Beverly earned her J.D. from the University of Maryland School of Law (2008) and her B.S. in Business Administration with a concentration in finance, with honors, from Bowie State University (2000), where she was named to the Dean’s List. She attended Bowie State on an athletic scholarship. She is admitted to practice in Maryland (2008) and before the U.S. Tax Court (2009).

• Recognition & Leadership

Beverly’s honors include the D.C. Pigskin Leadership Award and All-Conference CIAA recognition. A standout collegiate athlete, she received numerous honors at Bowie State—including selection to All-Conference, All-Regional, and All-Tournament teams—and remains the only woman in the history of the Central Intercollegiate Athletic Association (CIAA) to win three championships.

• Professional Involvement

Beverly is a member of the Maryland State Bar Association, the American Bar Association, the National Bar Association, and the National Society of Tax Professionals, and has served as a Board Member of the Fellowship of Christian Athletes (FCA) – Central Maryland from 2013 to present. She serves as the Clinical Law Instructor for the Low Income Taxpayer Clinic at the University of Maryland School of Law, where she is an Adjunct Law Professor and previously served as Director of the clinic.

• Experience

Beverly focuses her practice on tax resolution, representing individuals and businesses in matters before the IRS, including negotiating settlements, securing the release of liens and levies, and reducing clients’ tax debts. Before law school, she worked for local government doing budgeting and teaching entrepreneurial skills. She brings a competitive, client-focused approach to resolving tax problems and, through her firm’s affiliation with Winstead Tax Group, LLC, supports clients with both tax and accounting needs. She also serves as Director and Clinical Law Instructor for the Low Income Taxpayer Clinic at the University of Maryland Francis King Carey School of Law.

 

Barbara T. Kaplan, Esq., Shareholder | Greenberg Traurig

Barbara T. Kaplan is a Shareholder and Chair of the New York Tax Practice at Greenberg Traurig, LLP, based in the firm’s New York office. Named one of the top 50 women lawyers in New York City by Super Lawyers magazine, she 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.

• Education & Credentials

Barbara earned her LL.M. in Taxation from New York University School of Law (1979), her J.D., cum laude, from Brooklyn Law School (1975), her M.A. from Northwestern University (1972), and her B.A. from the University of Wisconsin–Madison (1970). She is admitted to practice in New York, and before the Supreme Court of the United States, the U.S. Court of Appeals for the Ninth Circuit, the U.S. District Courts for the Eastern and Southern Districts of New York, the U.S. Court of Federal Claims, and the U.S. Tax Court.

• Recognition & Leadership

Barbara is a Fellow of the American College of Tax Counsel and is rated AV Preeminent by Martindale-Hubbell. She has been listed in The Best Lawyers in America for Litigation and Controversy–Tax (2006–2026), including “Lawyer of the Year” for that category in 2020. She has been recognized by the International Tax Review as a World Tax Leader–Americas, “Highly Regarded” (2023, 2025, 2026) and a Women in Tax Leader (2025–2026); listed in the Chambers USA Guide (2010–2026) and Chambers High Net Worth Guide (2022–2025); included in Euromoney’s Expert Guides: Women in Business Law (2014, 2017, 2021–2022); recognized by Crain’s New York as a “Notable Woman in Law” (2019); and named a winner of Euromoney Legal Media Group’s Americas Women in Business Law Award for “Best in Tax Dispute Resolution” (2016). She has been listed in The Legal 500 United States for US Taxes: Contentious and Tax Controversy across multiple years, and in New York Metro Super Lawyers (2006–2025), including “Top 50 Women Lawyers in New York” (2007–2017) and “Top 100 Lawyers in New York” (2009–2010).

• Professional Involvement

Barbara is a member of the Tax Sections of the American and New York State Bar Associations, the American Association for Justice, the National Association of Criminal Defense Lawyers, and the Bar Association of the City of New York. She served on the Advisory Board of the New York University Institute on Federal Taxation (1989–1996) and on the Executive Committee of the New York State Bar Association Tax Section (2001–2005). A contributor to the GT Israel Law Blog, she is a frequent speaker at tax conferences including the Practising Law Institute, the New York University Institute on Federal Taxation, the Tax Executives Institute, the American Conference Institute, the New Jersey Society of Certified Public Accountants, the Tax Section of the American Bar Association, the Foundation for Accounting Education, and the Bar Association of the City of New York.

• Experience

Barbara’s government experience includes service as a Trial Attorney in Regional Counsel and a Senior Trial Attorney in District Counsel at the Internal Revenue Service, as well as Instructor in the IRS Criminal Tax Attorneys Training Program. In private practice, her civil tax and ERISA litigation experience includes representing foreign corporations in transfer pricing and valuation litigation, representing a welfare benefit plan in ERISA litigation, challenging family limited partnerships in U.S. Tax Court, litigating partnership investments across numerous industries, refund litigation in the Court of Federal Claims, and an interpleader action in federal district court. In administrative tax proceedings, she has handled sensitive audits, offshore account reporting, penalty waiver and abatement claims, unified partnership (TEFRA) proceedings, façade easements, charitable contributions, transfer tax, tax shelters, REIT compliance, transfer pricing, unreasonable compensation, and sales and use tax cases. Her tax collection work includes negotiating installment agreements, offers in compromise, collection freezes, and interest and penalty abatements, removing tax liens, and advising on transferee liability. In tax fraud matters, she has completed voluntary disclosures involving undisclosed offshore accounts, non-filers, and tax fraud; represented corporations and individuals in federal and state administrative and grand jury criminal tax investigations; negotiated plea agreements; defended taxpayers in summons enforcement proceedings; and quashed subpoenas and IRS summonses. She also represents tax professionals before the IRS Office of Professional Responsibility in suspension and disqualification proceedings and counsels them on compliance with Circular 230.

 

Jeffrey D. Trevillion, Jr., Esq., CPA, Director | Crowe & Dunlevy

Jeffrey Trevillion is a director in Crowe & Dunlevy’s Oklahoma City office, assisting clients as a member of the Taxation Practice Group. An experienced trial lawyer and certified public accountant, Jeff develops comprehensive strategies for clients facing civil and criminal tax controversies, litigation, and federal criminal defense. He also focuses his practice on highly regulated industries and routinely represents clients before numerous law enforcement and regulatory agencies, including the U.S. Department of Justice (DOJ), the U.S. Attorney’s Offices, the Internal Revenue Service (IRS), the Oklahoma Tax Commission, and the State Attorney General. His extensive knowledge of U.S. tax law and civil tax procedure allows him to provide clients with representation in all phases of federal civil tax controversies regarding sensitive matters and bet-the-company cases.

• Education & Credentials

Jeff received his Juris Doctor (2007) and Master of Business Administration (2007) from the University of Oklahoma, earning law school honors including the A.L. Jeffrey Writing Award and recognition as a Ford Scholar and Royce Savage Scholar. Prior to law school, he graduated cum laude from Langston University with a Bachelor of Business Administration in accounting (1999). He is admitted to practice in Oklahoma (2007) and Texas (2019), and before the Supreme Courts of Oklahoma and Texas, the U.S. District Courts for the Western and Northern Districts of Oklahoma, the U.S. Court of Appeals for the Tenth Circuit, and the U.S. Tax Court. He has been a Certified Public Accountant since 2003.

• Recognition & Leadership

Jeff has been listed in The Best Lawyers in America for Tax Law (2022). His honors include the Oklahoma Bar Association President’s Award (2012), the Oklahoma Bar Association Golden Gavel Award (2012), the Oklahoma Society of CPAs Trailblazer Award (2013), and the Oklahoma Bar Foundation President’s Award (2014). Active in the community, he has served on the board of directors or as a trustee for several legal organizations, including as Past Board President of the Oklahoma Bar Foundation (President, 2021), President of the Oklahoma County Bar Foundation (2017–2019), and Treasurer of the Oklahoma City Association of Black Lawyers (2008).

• Professional Involvement

Jeff is a member of the American Bar Association, Tax Section (Civil and Criminal Penalties Committee), the American Institute of Certified Public Accountants, Tax Section, the Federal Bar Association, Tax Section, the National Bar Association, Tax Section, the National Association of Criminal Defense Lawyers, the Oklahoma Criminal Defense Lawyers Association, the Oklahoma Society of Certified Public Accountants (2011–present), the Oklahoma Bar Association, and the State Bar of Texas, Tax Section Leadership Academy, and serves as a Criminal Justice Act (CJA) Panel Attorney for the Western District of Oklahoma. His recent speaking engagements include the “Criminal Tax Workshop” panel at the ABA National Institute on Criminal Tax Fraud & Tax Controversy (December 2022) and “A Primer on Collection Alternatives, Including Bankruptcy” at the ABA Section of Taxation 2022 Fall Tax Meeting. He has also taught classes for the Oklahoma Society of CPAs (a primer on IRC § 280E and IRS examinations and appeals) and the Oklahoma City Innovation District Workshop Series (best tax practices for startups).

• Experience

Jeff defends investigations conducted by the IRS Criminal Investigation Division (CID) and grand jury proceedings, civil tax suits by the DOJ Tax Division, and criminal prosecutions by U.S. Attorney’s Offices, and advises clients with sensitive “eggshell” audits that could potentially result in a criminal referral to the DOJ. His representative experience includes resolving a client’s foreign income tax dispute by full concession before the U.S. Tax Court and obtaining attorney’s fees from the IRS under 26 U.S.C. § 7430; representing a multi-state manufacturer and executive in an IRS trust fund recovery penalty assessment related to payroll taxes, resulting in a 75% reduction in penalty; defending a partnership with 30 partners facing the maximum penalty for failure to timely file Form 1065; representing a medical equipment provider in an Oklahoma sales tax dispute involving durable medical equipment exemptions, resulting in a 70% reduction in the audit assessment; representing a healthcare provider in a contract and Medicaid reimbursement dispute; representing a physicians’ group in an income tax controversy involving compliance and collection activity; defending a tax preparer in an IRS CID investigation; defending a taxpayer federally indicted on charges of filing false tax returns; representing a witness subpoenaed to a multi-county grand jury investigation; and defending mental health services providers in concurrent state and federal Medicaid fraud investigations.

 

Jessica Marine, Esq., Partner | Frost Law

Jessica Marine is a Partner at Frost Law, based in the Tampa Bay area, who brings over 18 years of dedicated experience in tax controversy. As a highly regarded tax specialist, Jessica delivers legal counsel to a diverse clientele, both domestically and internationally. Her comprehensive experience encompasses all phases of federal and state tax controversies, including litigation, with particular experience in IRS collections and U.S. Tax Court proceedings. She provides high-caliber legal services in tax, business, and litigation matters.

• Education & Credentials

Jessica holds an LL.M. in Taxation (2008) and a Juris Doctor, magna cum laude (2007), both from the University of Baltimore School of Law, and a Bachelor’s degree in Economics and Political Science, cum laude, from Bryn Mawr College (2004). She is admitted to practice in Maryland, as well as before the U.S. Tax Court, the U.S. District Court for the District of Maryland, and the U.S. Court of Appeals for the Fourth Circuit.

• Professional Involvement

She previously taught Tax Practice & Procedure at the University of Baltimore School of Law.

• Experience

Jessica’s experience encompasses all phases of federal and state tax controversies, including litigation, with particular depth in IRS collections and U.S. Tax Court proceedings. Prior to her current role, she held several positions at the U.S. Tax Court, including Deputy Clerk of the Court, where she spearheaded the Court’s case services division and led the development of its new case management system (DAWSON). She also taught Tax Practice & Procedure at the University of Baltimore School of Law. Born and raised on Maryland’s Eastern Shore, she is now based in the Tampa Bay area.

 

Jeffrey M. Sklarz, Esq., Founding Partner | Green & Sklarz

Jeffrey M. Sklarz is a Founding Partner of Green & Sklarz LLC, based in New Haven, Connecticut. Jeff’s practice is focused on representing businesses and individuals with complex financial litigation needs, including bankruptcy and bankruptcy litigation, creditor/debtor litigation, tax litigation, and commercial litigation. He regularly tries cases and appeals before Connecticut’s state and federal courts and has particular experience regarding the interplay between bankruptcy and tax law. He typically serves as counsel to clients experiencing a wide array of financial challenges, often involving “bet the company” matters.

• Education & Credentials

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. in Taxation from Boston University Graduate Tax Program

• Recognition & Leadership

Jeff is a Fellow of the American College of Tax Counsel. He was named the Best Lawyers 2022 “Lawyer of the Year” for Bankruptcy and Creditor Debtor Rights / Insolvency and Reorganization Law in New Haven and was included in the 2021 edition of The Best Lawyers in America for that practice area. He is a 2005 recipient of the Connecticut Law Tribune’s New Leaders of the Law Award (Overall Achievement, Fairfield County), has been listed by New England Super Lawyers as a Super Lawyer in Business Litigation since 2010 (Rising Star 2010–2013), and was named a Fellow of the American Bar Association, Business Law Section (2011–2013).

• Professional Involvement

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. His 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. He is the co-founder of the New England IRS Representation Conference and currently serves as President of the New Haven Jewish Community Center.

• Experience

Jeff regularly serves as counsel to clients facing a wide array of financial challenges, typically involving some form of “bet the company” matter. In financial restructuring and bankruptcy, he has served as counsel to debtors-in-possession across numerous industries (finance, real estate, aerospace, medical and medical devices, construction, specialty mill working, hospitality and recreation, the legal profession, manufacturing, energy, and industrial); as counsel to unsecured creditors committees, liquidating custodians, and liquidation trustees; as counsel to ad hoc committees of creditors and to debtors in out-of-court workouts; in the prosecution and defense of preference, fraudulent transfer, and avoidance actions; and as counsel to Chapter 7 trustees. In tax litigation, his work includes the resolution of criminal tax investigations, civil tax controversies including trials in U.S. Tax Court, successful abatement of employment tax penalties assessed on account of internal fraud by a controller, successful abatement of federal excise tax penalties for a major fuel installation, resolution of sales tax liability with the Connecticut Department of Revenue Services, and workout and resolution of tax shelter matters. Among his notable tax victories, he secured a 2021 Connecticut federal district court summary judgment ruling (with co-counsel Jeff Neiman) holding that the non-willful FBAR penalty is capped at $10,000 per form rather than per account—a matter of first impression for the court—and represented the taxpayer in Anikeev v. Commissioner, in which the U.S. Tax Court held that credit card rewards points were largely not taxable income. In commercial litigation, he has handled civil and jury trials in state and federal courts, including the successful defense of an independent trustee in a three-month jury trial and an apparel business in a month-long jury trial, the prosecution and defense of fraudulent transfer matters, litigation against long-term disability insurers, and the defense of a medical products manufacturer in a replevin action.

 

Lindsay L. Clayton, Esq., Assistant Chief | Western Civil Trial Section, Tax Division, US Department of Justice

Lindsay L. Clayton is an Assistant Director in the Tax Branch of the U.S. Department of Justice’s Civil Division, where she oversees and reviews attorneys litigating civil tax cases nationwide, focused in the Ninth and Tenth Circuits. She has played a key role in the litigation of regulatory challenges under the Administrative Procedure Act, employee retention credits, foreign banking and information reporting penalties, complex corporate and individual Chapter 11 bankruptcies, IRS summons disputes, jeopardy levies, white-collar fraud, tax procedure, and listed transactions.

• Education & Credentials

Lindsay graduated summa cum laude from Dartmouth College in 2004 with a Bachelor of Arts in Economics, and earned her law degree from Yale Law School in 2007.

• Recognition & Leadership

Lindsay is a regular instructor at the Department of Justice’s National Advocacy Center on topics including dispositive motions practice, negotiation, and civil discovery. Before the Tax Division’s dissolution in 2025, she served as an Assistant Chief with the Western Civil Trial Section. Among her notable accomplishments, she successfully obtained a writ of ne exeat republica, one of a handful historically sought by the Department.

• Professional Involvement

Lindsay is a regular instructor at the Department’s National Advocacy Center, teaching on dispositive motions practice, negotiation, and civil discovery, and is a speaker at the 2026 D.C. Bar Tax Conference on the panel “Tax Controversy: Regulatory Validity Challenge Trends Since Loper Bright and its Potential Impact on the OBBBA and Future Tax Legislation.”

• Experience

Lindsay serves as an Assistant Director in the Tax Branch of the DOJ’s Civil Division, overseeing and reviewing attorneys litigating civil tax cases nationwide with a focus on the Ninth and Tenth Circuits. Before the Tax Division’s dissolution in 2025, she was an Assistant Chief with the Western Civil Trial Section, where she played a key role in litigating regulatory challenges under the Administrative Procedure Act, employee retention credits, foreign banking and information reporting penalties, complex corporate and individual Chapter 11 bankruptcies, IRS summons disputes, jeopardy levies, white-collar fraud, tax procedure, and listed transactions. Before 2017, she served as a Tax Division Trial Attorney, handling a varied docket including complex estate and gift tax issues, research credits, the domestic production activities deduction, and the extraterritorial income exclusion regime, during which she handled both jury and bench trials and engaged in extensive civil discovery and motions practice. Before joining the Department, she spent three years as an associate with the Washington, D.C. office of Skadden, Arps, Slate, Meagher & Flom LLP.

 

Andrew Strelka, Esq., Partner | Willkie Farr & Gallagher

Andrew Strelka is a partner in Willkie’s Tax Department and Chair of the Tax Resolution Practice Group, based in the firm’s Washington, DC office. Andrew has significant tax experience in a variety of government and private practice roles and is nationally recognized for his work in tax-related disputes, litigation, and investigations. He advises on a comprehensive range of tax controversy matters with particular focus on tax litigation, IRS appeals, exempt organizations, Administrative Procedure Act issues, and transfer pricing issues. His clients span a variety of industries, including global nonprofits, private equity, technology, and global financial institutions.

• Education & Credentials

Andrew earned his LL.M. from Georgetown University Law Center (2010), his J.D. from American University (2008), and his B.A. from the University of Virginia (2002). He is admitted to practice in Connecticut, the District of Columbia, and New York.

• Recognition & Leadership

Andrew is a Fellow of the American College of Tax Counsel and a Fellow of the Foundation of the Federal Bar. His honors include the Outstanding Attorney Award from the U.S. Department of Justice, Tax Division (2013), and the Younger Federal Lawyer Award from the Federal Bar Association (2012). His government career included service as Senior Tax Counsel in the Biden White House and a tax advisory role in the Obama White House.

• Professional Involvement

Andrew is a Fellow of the American College of Tax Counsel and the Foundation of the Federal Bar, and serves as a Sections-Division Council Member of the Federal Bar Association, having previously served as National Chair of the Federal Bar Association Section on Taxation (2013–2014). He is an active author and lecturer, with selected publications including “The Corporate AMT’s Crypto Problem Has Constitutional Hazards” (Tax Notes Federal, 2024), “Corporate AMT’s Shadow Grows as FASB Goes Mark-to-Market” (Tax Notes Federal, 2024), “The IRS and America’s Longest Running ADR Program” (The Federal Lawyer, 2016), “The IRS’s Use of Secret Subpoenas” (The Federal Lawyer, 2016), “Bankruptcy Tax Litigators: The Unicorns of Federal Tax Litigation” (The Federal Lawyer, 2014), and “They Actually Put That in Writing? Common Mistakes in Written Tax Advice” (2026).

• Experience

Andrew has significant tax experience across government and private practice. Prior to joining Willkie, he was counsel at an international law firm. He previously served as Senior Tax Counsel in the Biden White House, where he advised on all manner of federal taxation issues and oversaw the vetting and Senate confirmation process. Earlier, he served as a trial attorney in the Department of Justice Tax Division, litigating a range of civil tax matters involving tax-exempt organizations, tax refund suits, Administrative Procedure Act matters, and transfer pricing disputes, and was detailed to the Obama White House in a tax advisory role. Prior to his DOJ tenure, he was a Presidential Management Fellow, splitting his time between the IRS—where he issued rulings and guidance on tax-exempt organizations—and the U.S. Attorney’s Office for the District of Columbia, representing the United States in complex civil litigation. His selected significant matters include Varian Medical Systems v. Commissioner, 163 T.C. No. 4 (2024)—the first Tax Court case to apply the Supreme Court’s new standard from Loper Bright Enterprises v. Raimondo, in which the court ruled a federal regulation invalid as it impermissibly overrode the clear statutory language and effective dates of the Tax Cuts and Jobs Act of 2017—and a lengthy U.S. Court of Federal Claims trial decided in 2023 in which a leading global bank was awarded a federal tax refund of $183 million plus interest following the government’s breach of contract (Andrew advised on some of these matters prior to joining Willkie).

 

Justin L. Campolieta, Esq., Partner | Jones Day

Justin L. Campolieta is a Partner in the Tax practice at Jones Day, based in the firm’s New York and Miami offices. With two decades of experience as a trial attorney for the Internal Revenue Service (IRS) Office of the Chief Counsel, Justin has overseen the development, litigation, and resolution of some of the largest and most complex tax cases in the United States. He has broad experience with administrative and judicial tax controversies involving a wide variety of procedural and substantive tax issues, including transfer pricing, tax evasion and fraud, financial products, tax treaties, cross-border information sharing, employment tax, collection due process, partnership taxation, administrative law, and a host of corporate and individual income tax issues. For the past decade, his practice has focused primarily on international tax matters, with a concentration on high-stakes transfer pricing controversies, typically involving the transfer and valuation of “crown jewel” intangibles by some of the largest corporate taxpayers in the world.

• Education & Credentials

Justin earned his J.D., magna cum laude, from the University of Miami (2004) and his B.A. from the State University of New York at Albany (2000). He is admitted to practice in Florida and the District of Columbia, and before the U.S. Tax Court and the U.S. District Court for the Southern District of Florida.

• Recognition & Leadership

Justin is a two-time recipient of the IRS Office of Chief Counsel National Litigation Award (2015 and 2022). His government service with the IRS Office of the Chief Counsel included roles as Senior Level Special Trial Attorney (Strategic Litigation), 2023–2024; Special Trial Attorney, Large Business and International (LB&I) Division, 2011–2023; and Attorney, Small Business/Self-Employed (SB/SE), 2004–2011.

• Professional Involvement

Justin is an active author and speaker on tax controversy matters. His recent publications include “Does Loper Bright Provide a Reason To Rethink Reasonable Cause?” (Tax Notes, June 2025), “Navigating Tariffs and Income Taxes and Transfer Pricing” (May 2025), and “U.S. Tax Court Invokes Loper Bright for the First Time” (August 2024). His recent speaking engagements include moderating the Civil Tax Litigation panel at the NYU 17th Annual Tax Controversy Forum (June 2025), presenting on transfer pricing disputes at the Tax Academy of Singapore’s International Tax Disputes Day (May 2025), speaking on recent tax cases and pending litigation at PLI’s Tax Controversy 2025 program, and presenting a tax litigation update at the DC Bar Tax Conference (2025).

• Experience

Justin’s experience with international tax matters extends both to the courtroom, where he served as lead counsel on large-scale transfer pricing controversies, and to dispute resolution within the IRS, the Office of Chief Counsel, and the Independent Office of Appeals, leading to reduced costs and greater certainty for the government and for taxpayers. In addition to his trial experience in the United States Tax Court, throughout his career he has advised revenue agents and officers and other IRS representatives and executives on all facets of tax administration, including examination, collection, litigation, settlement, and overall case development, and coordinated closely with the U.S. Attorney’s Office and the Department of Justice Tax Division at all significant stages of litigation in U.S. District Courts and the Court of Claims. He served with the IRS Office of the Chief Counsel as Senior Level Special Trial Attorney (Strategic Litigation, 2023–2024), Special Trial Attorney in the LB&I Division (2011–2023), and Attorney in the SB/SE Division (2004–2011).

 

Sandra R. Brown, Esq., Principal | Hochman Salkin Toscher Perez, PC

Sandra R. Brown is a Principal at Hochman Salkin Toscher Perez P.C., based in Beverly Hills, California, who joined the firm after serving most recently as the First Assistant United States Attorney for the Central District of California. Ms. Brown’s practice focuses on individuals and organizations involved in criminal tax investigations, including related grand jury matters, court litigation, and appeals, as well as representing and advising taxpayers involved in complex and sophisticated civil tax controversies, including sensitive-issue audits and administrative appeals, and civil litigation in federal, state, and tax court.

• Education & Credentials

She is admitted before the U.S. Court of Appeals for the Ninth Circuit, the U.S. Tax Court, the U.S. District Courts for the Central, Eastern, Northern, and Southern Districts of California, and the U.S. Court of Federal Claims.

• Recognition & Leadership

Ms. Brown has received the Internal Revenue Service Criminal Investigation Chief’s Award and the IRS’s Mitchell Rogovin National Outstanding Support of the Office of Chief Counsel Award—respectively the most prestigious criminal and civil awards available for presentation by the IRS to Department of Justice employees. She has been recognized as one of California’s top 100 leading women lawyers and is the recipient of the 2024 USD School of Law’s Richard Carpenter Excellence in Tax Award. She is a Fellow of the American College of Tax Counsel. From March 2017 to January 2018, she served as the Acting United States Attorney for the Central District of California, leading the largest Justice Department office outside of Washington, D.C., where she supervised approximately 270 attorneys, and she served as Chief of the Tax Division for more than ten years.

• Professional Involvement

Ms. Brown serves as Co-Chair of the ABA Criminal Tax Fraud and Tax Controversy Conference, Co-Chair of the UCLA Tax Controversy Institute, Co-Chair of Tax Controversy for the NYU Institute on Federal Taxation, and a member of the NYU Tax Controversy Institute Advisory Committee. Within the American Bar Association Tax Section, she is Sentencing Subcommittee Co-Chair of the Civil & Criminal Tax Penalties Committee, and she serves as a Mentor for the ABA Loretta Collins Argrett Fellowship. She is also a member of the Beverly Hills Bar Association (Taxation Section), the Federal Bar Association, the State Bar of California, the California Lawyers Association (Tax Section), and the Women White Collar Defense Association. A prolific author and highly sought-after speaker, she has written, lectured, and taught federal prosecutors, agents, and private practitioners throughout the country on trial strategies, taxation, bankruptcy, and money laundering, with extensive publications in the Journal of Tax Practice and Procedure, Los Angeles Lawyer, and Tax Notes, and recurring speaking roles at the ABA, NYU, USC, UCLA, and Hawaii tax institutes and conferences.

• Experience

In more than 26 years as a federal trial lawyer, Ms. Brown obtained a vast expanse and depth of experience in complex civil and criminal tax matters, having personally handled over 2,000 cases on behalf of the United States before the U.S. District Court, the Ninth Circuit Court of Appeals, the U.S. Bankruptcy Court, the U.S. Bankruptcy Appellate Panel, and the California Superior Court. Her government service included roles as Acting United States Attorney (2017–2018), First Assistant United States Attorney (2016–2018), Assistant United States Attorney in the Tax Division (1991–2016), Chief of the Tax Division (2004–2016), and Deputy Chief, Criminal Tax Matters (2003–2004). Her cases included nationally significant civil tax matters such as two Supreme Court decisions and numerous published Ninth Circuit decisions, as well as noteworthy criminal tax cases including the first of the recent FBAR prosecutions in California, one of the largest individual tax restitution judgments fully recovered in a criminal tax case prosecuted in the nation, and an unprecedented deferred prosecution agreement resolving a criminal probe into an international bank’s worldwide U.S. cross-border business that required the bank to pay $270 million in restitution and fines and to provide details about employees and more than 1,500 U.S. customers. In private practice at the firm, she represents individuals and organizations in criminal tax investigations, grand jury matters, litigation, and appeals, and advises taxpayers in sensitive-issue civil audits, administrative appeals, and civil tax litigation.

 

Joshua Wu, Esq., Deputy Assistant Attorney General for the Tax Litigation Branch | US Department of Justice, Civil Division

Joshua Wu serves as the Deputy Assistant Attorney General for the Tax Litigation Branch of the Civil Division of the U.S. Department of Justice, a role he has held since 2025. He rejoined the Department from Latham & Watkins LLP in Washington, D.C., where he practiced in the firm’s tax controversy and litigation group, counseling and advocating for companies and high-net-worth individuals on all aspects of tax controversies and litigation. He previously served at the Department from 2019 to 2021 as Deputy Assistant Attorney General for Appellate and Review in the Tax Division, where he oversaw virtually all appeals in civil federal tax cases throughout the country and managed a 40-lawyer team. In that role he also represented the United States in appellate oral arguments, evaluated and approved significant civil settlement offers, furnished advice to the Tax Division’s trial sections in complex tax cases, led the operational functions of the Tax Division, and led the Office of Legislation and Policy, which works with the Department of the Treasury, the IRS, and other agencies on legislative, regulatory, and policy initiatives.

• Education & Credentials

Josh earned his LL.M. in Taxation from the Georgetown University Law Center. He is a graduate of the Syracuse University College of Law and the University of Virginia.

• Recognition & Leadership

In October 2024, Josh was inducted as a Fellow of the American College of Tax Counsel, a nonprofit association of tax attorneys recognized for excellence in tax practice and substantial contributions to the
legal profession. Election as a Fellow requires nomination by a current Fellow and evaluation by a committee of the College’s Board of Regents, with membership criteria including bar membership in one or more states for at least 15 years, a career principally devoted to tax law and tax-related matters, and a demonstrated high standard of excellence and ethical conduct in the practice of tax law. He has also been identified by Legal 500 as a key practitioner within Latham & Watkins’ contentious tax practice.

• Professional Involvement

In private practice, Josh advised large companies and high-net-worth individuals on all aspects of federal tax law and controversies, with a practice focused on litigating high-stakes tax cases and representing clients in both civil and criminal tax controversy matters. His advisory work spans tax accounting disputes, corporate and partnership transactional issues, international questions, employee benefits matters, transfer pricing, and tax-exempt controversies. He has served as a featured speaker on tax matters, including on voluntary disclosure programs and the Section 199A pass-through deduction, and has presented before professional audiences such as CPA societies and international tax symposia.

• Experience

Joshua Wu serves as the Deputy Assistant Attorney General for the Tax Litigation Branch of the Civil Division (2025–Present), one of seven deputy assistant attorneys general in the Civil Division reporting to the Assistant Attorney General. Immediately before this role, he was counsel in the Tax Department and a member of the Tax Controversy Practice at Latham & Watkins LLP in Washington, D.C., where he advised companies, tax-exempt organizations, and high-net-worth individuals on resolving contentious tax matters. From 2019 to 2021, he served at the Department of Justice as Deputy Assistant Attorney General for Appellate and Review in the Tax Division, overseeing civil federal tax appeals nationwide, managing a 40-lawyer team, arguing appeals on behalf of the United States, approving significant civil settlements, advising the Tax Division’s trial sections, and leading the Office of Legislation and Policy. Earlier in his career he worked as an associate at Latham & Watkins and as a partner at a large international law firm.

 

Don Fort, CPA, Senior Investigator | Kostelanetz

John D. (Don) Fort is a Senior Investigator at Kostelanetz LLP and the former Chief of the Internal Revenue Service’s Criminal Investigation (CI) Division. Having spent nearly 30 years in law enforcement for the federal government, Don has deep expertise in financial crimes and an extensive network of connections both within the government and in private industry. At the firm, he 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, with particular expertise in investigations involving cryptocurrency and cannabis-related matters. He also conducts internal investigations, advises clients on compliance regimes, and is available as an expert witness and litigation consultant and for voluntary or court-mandated monitorships. Don currently provides his leadership and law enforcement expertise to the advisory boards of several fintech, anti-money laundering compliance, cryptocurrency, and cannabis compliance companies, including AML RightSource, ZenLedger, and NCS Analytics, and serves as Chief Business Officer with IVIX.

• Education & Credentials

Don holds a Bachelor of Arts degree in Management from Gettysburg College (1990) and is a licensed Certified Public Accountant in the State of Virginia.

• Recognition & Leadership

In 2020, Don was the recipient of the Association of Certified Anti-Money Laundering Specialists (ACAMS) Public-Private Partnership Award. As Chief of IRS-CI from 2017 to 2020, he 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 across 21 IRS field offices and 11 foreign countries. As both Chief and Deputy Chief, he oversaw numerous high-profile matters, including the “Varsity Blues” college admissions scandal; the Paul Manafort, Michael Cohen, and Michael Avenatti federal tax investigations; the takedown of the largest darknet child exploitation website funded by cryptocurrency; the prosecution of two Chinese nationals charged with laundering $100 million in a cryptocurrency exchange hack; the Swiss Bank Program, in which 80 Swiss banks entered agreements and paid $1.36 billion in penalties; the FIFA worldwide money laundering, structuring, and tax evasion matter; and the Credit Suisse guilty plea.

• Professional Involvement

Don is an accomplished public speaker who serves as an expert in law enforcement, leadership, financial crimes, and enhancing public-private partnerships. He has extensive experience briefing high-level government officials, has testified before Congress, and has provided numerous briefings to congressional staff. He serves on the advisory boards of several fintech, anti-money laundering, cryptocurrency, and cannabis compliance companies, including AML RightSource, ZenLedger, and NCS Analytics, and holds the role of Chief Business Officer at IVIX. He participates regularly in leading tax and economic crime programs, including the ABA Criminal Tax Fraud and Tax Controversy meeting, the Hawaii Tax Institute, and the Cambridge International Symposium on Economic Crime.

• Experience

Don served with the U.S. Department of the Treasury, Internal Revenue Service, Criminal Investigation (IRS-CI) from August 1991 to September 2020, spending the final nine years as a member of the Senior Executive Service. He began as a Special Agent in the Washington, D.C. Field Office (1991–1999), then served as Supervisory Special Agent in Orlando (1999–2003); Section Director/Senior Analyst for Special Investigative Techniques in Washington, D.C. (2003–2006); Assistant Special Agent in Charge of the Baltimore and Washington, D.C. Field Offices (2006–2009); Special Agent in Charge of the Philadelphia Field Office (2009–2010); Deputy Director of Strategy at Washington, D.C. Headquarters (2010–2011); Director of Field Operations for the Western and Northern Areas (2011–2014); Deputy Chief of IRS-CI (2014–2017); and Chief of IRS-CI (2017–2020). His tenure included oversight of investigations into 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. Since leaving government in 2020, he has served as Director of Investigations and now Senior Investigator at Kostelanetz LLP, operating out of the firm’s Washington, D.C. office.

 

Guy Ficco, CFE, Senior Investigator | Kostelanetz

Guy Ficco is a Senior Investigator at Kostelanetz LLP and the immediate past Chief of IRS Criminal Investigation (IRS-CI). As Chief and Deputy Chief of IRS-CI from 2022 through April 2026, Guy directed one of America’s largest federal law enforcement organizations, overseeing operations with an annual budget exceeding $1 billion and leading a global workforce of approximately 3,500 personnel, including more than 2,300 special agents deployed across 20 domestic field offices and operations in 14 international locations. Throughout his law enforcement career, he spearheaded investigations into major financial crimes spanning tax evasion, sanctions violations, money laundering, corruption, banking misconduct, cybercrime, cryptocurrency offenses, and terrorism financing. At the firm, he draws on more than 30 years of federal law enforcement experience to advise clients on matters including criminal tax exposure, parallel civil-criminal investigations, Bank Secrecy Act and anti-money laundering issues, cryptocurrency enforcement, corporate compliance, and cross-border financial crime.

• Education & Credentials

Guy earned his Bachelor of Business Administration degree, with a concentration in accounting, from Dominican University (New York). He is a Certified Fraud Examiner and maintains professional memberships in both the Association of Certified Fraud Examiners (CFE) and the Association of Certified Sanctions Specialists.

• Recognition & Leadership

During Guy’s tenure, IRS-CI achieved record enforcement results, expanded its international footprint, and strengthened collaboration with domestic and foreign law enforcement agencies. In his roles as both Chief and Deputy Chief, he directed several landmark investigations, including Janet Mello’s $100 million grant fraud scheme, a $1 billion syndicated conservation easement tax fraud conspiracy, the comprehensive $1 billion Bank Secrecy Act and IEEPA investigation of Binance, a major biofuel tax conspiracy, and multiple prominent darknet marketplace cases involving narcotics trafficking, cybercrime, identity theft, and child exploitation materials. He co-chaired the Treasury Department’s Fentanyl Strike Force and led IRS-CI’s participation in the United States’ “Task Force KleptoCapture” following Russia’s invasion of Ukraine. His international leadership roles included serving on the Executive Policy Board for the International Law Enforcement Academy (ILEA), active participation in the OECD Task Force on Tax Crimes and Other Crimes (TFTC), and chairing the OECD Tax Crimes Enforcement Network (TCEN). He also represented the United States as Chief of IRS-CI as part of the Joint Chiefs of Global Tax Enforcement (J5).

• Professional Involvement

As an established expert in financial crime enforcement, Guy regularly addresses domestic and international audiences on complex white-collar fraud, cryptocurrency investigations, and anti-money laundering compliance. Under his leadership, IRS-CI launched an innovative Public-Private Partnership initiative (CI FIRST) designed to foster collaboration between law enforcement and Bank Secrecy Act filers, including financial institutions, casinos, and money service businesses. He championed a data-driven transformation within IRS-CI, cultivating a new generation of analytically minded leaders and introducing innovations such as an artificial intelligence tool that assesses prosecution likelihood during investigation initiation phases. He completed a congressional fellowship with the Permanent Subcommittee on Investigations for Homeland Security and Governmental Affairs, contributing to oversight investigations examining international tax shelters, corporate stock option abuses, and credit card fraud, and he has regularly briefed senior government officials and congressional staff on critical matters. He maintains memberships in the Association of Certified Fraud Examiners and the Association of Certified Sanctions Specialists.

• Experience

Guy began his IRS career in 1995 as a Special Agent in New York, progressively advancing through various supervisory positions before joining the Senior Executive Service in May 2020 as Executive Director of Global Operations, a role he held until his appointment as Deputy Chief in July 2022. He subsequently served as Chief of IRS-CI, leading the agency through April 2026. Across his career he held a range of CI leadership roles, including Special Agent in Charge of the Philadelphia Field Office (2018–2020), Supervisory Special Agent in the Washington Field Office, and senior analyst and executive positions spanning financial crimes, international operations, and global policy and support. During his tenure as Chief and Deputy Chief, he oversaw the agency’s worldwide enforcement operations and directed many of its most consequential domestic and cross-border criminal tax and financial crime investigations. Since leaving government in 2026, he has served as a Senior Investigator at Kostelanetz LLP.

 

Jarod Koopman, Chief, Criminal Investigation Division; Chief Tax Compliance Officer | Internal Revenue Service

Jarod Koopman is the Chief of IRS Criminal Investigation (IRS-CI) and the agency’s Chief Tax Compliance Officer. He stepped into the Chief role after more than 26 years with the IRS, including over two decades within IRS-CI, where he has held leadership positions at multiple levels. As Chief of IRS-CI, he leads a global workforce of approximately 3,000 personnel, including more than 2,100 special agents operating across 20 field offices and 11 international locations. As Chief Tax Compliance Officer, he oversees IRS compliance operations across several major divisions and offices, including the Large Business and International division, the Small Business/Self-Employed division, the Tax Exempt and Government Entities division, IRS Criminal Investigation, the Office of Professional Responsibility, the Return Preparer Office, and the Whistleblower Office. He is widely respected as a global leader in cryptocurrency tracing and dark web investigations.

• Education & Credentials

A native of Upstate New York, Jarod is a graduate of Nazareth University in Rochester. He began his law enforcement career in 2002 following his training at the Federal Law Enforcement Training Center (FLETC), excelling in both FLETC’s Criminal Investigator Training Program and IRS-CI’s Special Agent Basic Training Program and graduating at the top of his class.

• Recognition & Leadership

Under Jarod’s leadership, IRS-CI significantly enhanced its capabilities, establishing itself as a global leader in cryptocurrency tracing and dark web investigations. As director of cybercrime for IRS-CI, he helped achieve major wins against crimes involving cryptocurrency, including the dismantling of the Silk Road dark web marketplace, which led to the government seizing $3.36 billion worth of bitcoin. In 2011 he was selected for the Accelerated Senior Leadership Program (ASLP). Upon his appointment as Chief, IRS-CI publicly recognized that over his then-26-year career he had established himself as a leader and innovator within the agency. His work has also been recognized in the bestselling book Who Is Government? by Michael Lewis and featured in the Washington Post series “Cyber Sleuth.”

• Professional Involvement

Jarod is recognized as an expert on financial crime, cryptocurrency tracing, and anti-money laundering enforcement, and he addresses law enforcement and compliance audiences on these topics, including as a speaker at the 2026 West Coast Anti-Money Laundering (WCAML) Forum. In 2015, he was tasked with establishing and leading IRS-CI’s Cyber Crimes and Cyber and Forensics Services sections, serving as Director of both. Earlier in his career, after transitioning to IRS Headquarters as a Senior Analyst, he worked under the direction of the National Identity Theft Coordinator, contributing to the agency’s heightened focus on identity theft as a national priority in 2012.

• Experience

Jarod began his law enforcement career with the IRS in 2002 as a special agent in Rochester, New York. In April 2010, he was promoted to Supervisory Special Agent for the Western District of New York, and the following year he was selected for the Accelerated Senior Leadership Program and transitioned to IRS Headquarters as a Senior Analyst, working under the National Identity Theft Coordinator. Beginning in 2015–2016 as a CI executive, he led the creation and development of both the Cyber Crimes and Cyber and Forensics Services sections, serving as Director of each. He later served as Assistant Special Agent in Charge of the Chicago Field Office, then as Special Agent in Charge of the Detroit Field Office, and as Executive Director of Northern Field Operations, overseeing criminal investigative activities across 17 states. In October 2025 he was named Acting Chief Tax Compliance Officer, overseeing the agency’s enforcement divisions, and effective April 2026 he was named Chief of IRS Criminal Investigation while continuing to serve as Chief Tax Compliance Officer.

 

Karen E. Kelly, Esq., Partner | Kostelanetz

Karen Kelly is a Partner in the Washington, D.C. office of Kostelanetz LLP and the former head of the Justice Department’s Tax Division. She joined the firm after more than 30 years of federal and state trial practice, including prosecuting tax and white-collar crime. Her practice focuses on representing clients in state and federal civil tax controversies, defending clients in government investigations involving criminal tax and white-collar matters and against state and federal criminal charges, conducting internal investigations, representing legal and tax professionals and their firms in license and regulatory matters, and complex civil and criminal litigation. She most recently served at the Department of Justice as the Acting Assistant Attorney General and delegated component head of the Tax Division, where she supervised all federal civil and criminal tax matters assigned to the Department throughout the country, along with more than 300 trial and appellate attorneys. First and foremost a litigator, Karen led and managed hundreds of sophisticated grand jury investigations and criminal tax jury trials in federal district courts nationwide.

• Education & Credentials

Karen received her law degree, cum laude, from Syracuse University College of Law and her bachelor’s degree from the College of the Holy Cross. She is admitted to practice in the District of Columbia and the Eastern District of Virginia.

• Recognition & Leadership

Karen received numerous commendations recognizing her extraordinary government service. She was twice honored with the Department of Justice Attorney General’s Award — among the highest service awards issued by the Department — including the Attorney General’s Award for Outstanding Service (2014) and the Attorney General’s Distinguished Service Award (2011) for her contributions as a member of a public corruption task force. She received the IRS Criminal Investigation Chief’s Award (2007) for her successful prosecution of a telecommunications entrepreneur who evaded more than $200 million in taxes — the largest individual income tax evasion case at the time — as well as the Department of Justice Executive Office Director’s Award for Superior Performance in Litigation (2009). She has been the recipient of more than a dozen Tax Division Outstanding Attorney Awards (2000, 2002, and 2005 through 2018), the Department of Justice Outstanding Mentor Award (2010), and the United States Attorney’s Office for the District of Columbia Outstanding Merit recognition (2003).

• Professional Involvement

Karen is a member of the American Bar Association (Section of Taxation; White Collar and Criminal Litigation), the National Association of Criminal Defense Attorneys (Lawyers), the Virginia State Bar (Section of Taxation; Litigation), and the Virginia Women’s Attorney Association. She currently serves on the Virginia State Bar Disciplinary Committee, reviewing attorney disciplinary complaints and investigations and conducting disciplinary hearings, having also served on the Committee from 2014 through 2018. A frequent lecturer, she has presented at U.S. Attorneys’ Offices on tax crimes, grand jury investigations, trial practice, and prosecutions, and as part of her government service she trained dozens of attorneys, law enforcement agents, and IRS personnel in the United States and abroad — including at the Justice Department’s training center in South Carolina, at IRS Field Offices, and in international engagements with Serbian law enforcement and the Barbados Revenue Authority. She regularly speaks on tax enforcement issues at ABA-sponsored conferences and other tax bar events.

• Experience

Karen served with the Tax Division of the U.S. Department of Justice in Washington, D.C., as Delegated Component Head and Acting Deputy Assistant Attorney General (2025), Chief of the Southern Criminal Enforcement Section (2019–2025), Assistant Chief of the Northern Criminal Enforcement Section (2008–2019), and Trial Attorney in the Northern Criminal Enforcement Section (1997–2008). During her career as a federal prosecutor she handled crimes including tax evasion, conspiracy, payroll tax fraud, obstruction, money laundering, FBAR violations, false claims, nominee entities, identity theft, false tax filings, and complex tax shelters, and she assisted with the Department’s Swiss Bank Program and resolved complex offshore entity investigations. As Assistant Chief and later Chief, she worked with federal prosecutors in more than 40 U.S. Attorneys’ Offices, coordinated and managed the Tax Division criminal portfolio, and built a strong working relationship with IRS Criminal Investigation; her successes include the first successful criminal prosecution of multiple professionals involved in the creation and promotion of a syndicated conservation easement tax shelter. She also served as a Special Assistant U.S. Attorney in the Southern District of New York (white-collar prosecutions) and in the Southern District of California (immigration and narcotics crimes), and earlier prosecuted state crime as an Assistant Commonwealth’s Attorney in Fairfax County, Virginia (1994–1997). Since 2025, she has practiced as a Partner at Kostelanetz LLP.

 

Scott Levine, Esq., Partner | Baker McKenzie

Scott Levine is a partner in Baker McKenzie’s Tax Practice Group, based in the Firm’s Washington, D.C. office. Prior to joining the Firm, Scott most recently served as the Deputy Assistant Secretary (International Tax Affairs) in the U.S. Department of the Treasury, where he led the Office of Tax Policy’s work on international affairs, including regulations, treaties, and the OECD/G20 Inclusive Framework on BEPS negotiations on Pillar 1 and Pillar 2. He has significant experience advising multinational companies on the tax aspects of corporate transactions, including cross-border and domestic mergers and acquisitions, spin-offs and other divestitures, restructurings, financing, and joint ventures, and he has negotiated private letter rulings with the Internal Revenue Service in the corporate, international, financial instruments, and energy tax credit areas.

• Education & Credentials

Scott earned his J.D. from American University (1997) and his B.A., cum laude with distinction, from the University of Pennsylvania (1994). He is admitted to practice in the District of Columbia (2006) and Florida (1997).

• Recognition & Leadership

Scott is a Fellow of the American College of Tax Counsel and is ranked in Chambers USA. He has been recognized in The Best Lawyers in America for Tax Law and named among Washingtonian Magazine’s Washington’s Top Lawyers (Tax). He received the Distinguished Service Award from the U.S. Department of the Treasury and was the inaugural recipient of the DC Bar’s Trailblazer Award for the Taxation Community.

• Professional Involvement

Scott is a member of the ABA Tax Section Nominating Committee and is the former Chair of the ABA Corporate Tax Committee. Within the DC Bar, he serves as Chair of the Annual Tax Legislative and Regulatory Update Conference and previously served as Chair of the Tax Section Corporate Tax Committee and as a two-term member of the Tax Section Steering Committee. He is an active author and commentator on international and corporate tax developments, including the OECD Model Tax Convention, Pillar Two, and recent U.S. tax legislation.

• Experience

Scott advises multinational companies on the tax aspects of corporate transactions, including cross-border and domestic mergers and acquisitions, spin-offs and other divestitures, restructurings, financing, and joint ventures, and he negotiates private letter rulings with the IRS in the corporate, international, financial instruments, and energy tax credit areas. Immediately prior to joining Baker McKenzie, he served as Deputy Assistant Secretary for International Tax Affairs at the U.S. Department of the Treasury through
the end of the Biden Administration, leading the Office of Tax Policy’s work on international tax affairs — including regulations, treaties, and the OECD/G20 Inclusive Framework on BEPS negotiations on Pillar 1 and Pillar 2. His practice areas span Tax, Tax Disputes, Tax for M&A and Reorganizations, Tax Policy, and Financial Services Regulatory matters.

 

Shelley Leonard, Esq., Deputy Tax Legislative Counsel | Office of Tax Policy, US Department of the Treasury

Shelley Leonard is Deputy Tax Legislative Counsel in the U.S. Department of the Treasury’s Office of Tax Policy, where she reviews and advises on domestic tax regulations and other guidance. She previously served as Acting Assistant Secretary for Tax Policy and Acting Deputy Assistant Secretary for Tax Policy. Prior to these Treasury roles, she served as a Legislation Counsel at the Joint Committee on Taxation, where she advised on legislative and policy matters relating to tax administration and compliance, individual income tax, health, employment tax, and certain business tax credits. Earlier in her Treasury tenure, she was Deputy Tax Legislative Counsel and an Attorney-Advisor in the Office of Tax Policy, and she has also worked in private practice in the tax group of a law firm, focusing on federal tax controversy, litigation, and counseling. She began her legal career as a trial attorney for the U.S. Department of Justice, Tax Division.

• Education & Credentials

Shelley received her B.A., cum laude, from Dartmouth College and her J.D., cum laude, from Harvard Law School.

• Professional Involvement

Shelley is an active participant in the tax policy community, serving as a speaker at the D.C. Bar Tax Conference — including a panel on recent guidance on clean energy tax credits — and at the D.C. Bar Tax Legislative and Regulatory Update Conference.

• Experience

Shelley currently serves as Deputy Tax Legislative Counsel in the Treasury’s Office of Tax Policy, where she reviews and advises on domestic tax regulations and other guidance, and she has served in the acting capacities of Assistant Secretary for Tax Policy and Deputy Assistant Secretary for Tax Policy. Before her current role, she was a Legislation Counsel at the Joint Committee on Taxation, advising on legislative and policy matters relating to tax administration and compliance, individual income tax, health, employment tax, and certain business tax credits. Earlier, she served as Deputy Tax Legislative Counsel and as an Attorney-Advisor in the Office of Tax Policy, and she practiced as an associate in the tax group of a law firm in the areas of federal tax controversy, litigation, and counseling. She began her legal career as a trial attorney with the U.S. Department of Justice, Tax Division, and earlier served as a law clerk to the Honorable Michael Baylson in the U.S. District Court for the Eastern District of Pennsylvania.

 

Pamela Grewal, Esq., Managing Director | Andersen Tax

Pamela Grewal is a Managing Director in the US National Tax practice at Andersen, based in San Francisco. She draws on over 17 years of government experience to assist clients in navigating federal tax controversy matters. After launching her career at the Department of Justice Tax Division, she transitioned to the IRS Counsel’s National Office in Washington, D.C., where she advised IRS and DOJ personnel on emerging issues in the tax-exempt organizations sector and drafted letter rulings and regulations. Upon relocating to the San Francisco office, her legal expertise expanded significantly: she litigated cases for various divisions — including TEGEDC, LBI, SB/SE, and Strategic Litigation — and advised numerous examination teams on a wide range of issues, including Indian tribal government affairs, employment taxes, research credits, and transfer pricing.

• Education & Credentials

Pamela earned her B.A. in Economics from Pomona College and her J.D. from The University of Michigan Law School.

• Recognition & Leadership

Pamela is, a sought-after speaker on tax controversy matters, having presented at leading national programs including the Practising Law Institute’s Nuts and Bolts of Tax Controversy and its Tax Strategies conference, UCLA’s Tax Controversy Conference, the ABA Tax Section’s Criminal Tax Fraud and Tax Controversy Conference, and the ABA’s Fall Tax Meeting, and she has served as a co-chair of the NYU Tax Controversy Forum.

• Professional Involvement

Pamela is a member of the California Bar Association, the Maryland State Bar Association, the American Bar Association (Tax Section), and the Federal Bar Association, and she is admitted before the United States Tax Court. She is an active panelist and commentator on federal tax controversy developments, including agency deference following the Supreme Court’s Loper Bright decision, the Employee Retention Credit, and other enforcement priorities.

• Experience

Pamela brings more than 17 years of federal government experience to her practice. She began her career as a trial attorney at the Department of Justice Tax Division, then served in the IRS Counsel’s National Office in Washington, D.C., advising IRS and DOJ personnel on emerging tax-exempt organization issues and drafting letter rulings and regulations. After relocating to San Francisco, she litigated cases on behalf of the government for multiple divisions — including TEGEDC, LBI, SB/SE, and Strategic Litigation — and provided technical guidance to examination teams on matters such as Indian tribal government affairs, employment taxes (including worker classification and withholding), research credits, and transfer pricing. Immediately before joining Andersen, she served as a Special Trial Attorney in the IRS’s Strategic Litigation division, where she litigated complex cases of national significance on behalf of the government. She now advises clients on federal tax controversy matters in Andersen’s US National Tax practice.

 

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

Erin M. Collins is the National Taxpayer Advocate, appointed to the role in March 2020 by Secretary Mnuchin. In this position she oversees the Taxpayer Advocate Service (TAS) and serves as the “Voice of the Taxpayer” within the IRS and before Congress. TAS operates as a “safety net” for taxpayers by advocating for the resolution of individual and business taxpayer issues within the IRS, and it also administers the Low Income Taxpayer Clinic federal grant program and the Taxpayer Advocacy Panel. As National Taxpayer Advocate, Erin identifies and works toward systemic changes for all taxpayers while protecting taxpayer rights, and through her Annual Report to Congress she advances administrative and legislative changes intended to protect those rights and improve the quality of taxpayer service and tax administration as an independent voice inside the IRS. She regularly testifies before the Senate Finance Committee, the U.S. House Ways and Means Committee Oversight Subcommittee, and the Senate Appropriations Subcommittee on tax administration and taxpayer rights.

• Education & Credentials

She has over 35 years of experience in tax law and previously spent 15 years in the IRS Office of Chief Counsel and 20 years at KPMG LLP.

• Recognition & Leadership

Erin has received broad recognition across the accounting and tax professions. In 2022, the American Institute of CPAs (AICPA) and CPA Practice Advisor selected her as one of the top 25 Most Powerful Women in the Accounting Profession; Accounting Today recognized her as one of the 100 Most Influential People in Accounting; and Money.com named her a Changemaker among 50 Innovators Shaping Americans’ Finances. In 2023, she received KPMG’s Fifth Annual Network of Women Alumni Legacy Award and the California Lawyers Association’s Joanne M. Garvey Lifetime Achievement Award, and Accounting Today again named her one of the 100 Most Influential People in Accounting. The UCLA Extension Tax Controversy Institute selected her to receive the Bruce I. Hochman Award in recognition of her proficiency in tax law and her leadership, and Accounting Today again recognized her on its top 100 list in 2024.

• Professional Involvement

Erin is frequently cited in national news media and tax publications and appears annually as a guest on C-SPAN’s Washington Journal program. She is co-author of the Practising Law Institute’s IRS Practice and Procedure Deskbook and frequently speaks on IRS practice, procedure, controversy, and litigation matters before professional organizations and on government and tax-industry podcasts. Before joining TAS, she represented several clients pro bono to help resolve issues with the IRS and served as a volunteer and board member of the non-profit Step Up, which helps girls in under-resourced communities become confident, college-bound, and career-focused.

• Experience

Erin has more than 35 years of experience in tax law, spanning 15 years in the IRS Office of Chief Counsel and 20 years at the accounting firm KPMG LLP, where she retired in 2019 as the Tax Managing Director in charge of the firm’s tax controversy practice for the Western region. Throughout her KPMG career she represented thousands of individuals, partnerships, small companies, and corporate taxpayers in federal examinations, IRS appeals, and before the U.S. Tax Court on domestic and international tax issues. Since March 2020, she has served as the National Taxpayer Advocate, leading TAS and delivering the statutory Annual Report and mid-year Objectives Report to Congress.

 

Meghan R. Biss, Esq., Partne |, Loeb & Loeb

Meghan R. Biss is a Partner at Loeb & Loeb LLP who counsels tax-exempt and nonprofit organizations at every stage of their lifecycle, advising on tax planning, compliance, and audit matters. As a former senior advisor in the Internal Revenue Service (IRS) Exempt Organizations division, she leverages over 10 years of government experience to guide clients through interactions with the IRS, the U.S. Department of the Treasury, and other government agencies. She represents a diverse array of organizations, including private foundations, national and foreign charities, social welfare organizations, colleges and universities, lobbying and political organizations, and trade associations. Meghan guides clients through applications for tax-exempt status, private letter ruling requests, and other IRS submissions; advises private foundations on excise tax issues; supports the development of compliant programmatic activities; and conducts mock audits and compliance reviews to help organizations strengthen their positions ahead of examinations. She also advises clients in tax controversy matters — including audits, investigations, and litigation involving tax-exempt status and public charity classification — and represents organizations before the U.S. Tax Court.

• Education & Credentials

Meghan earned her J.D., cum laude, from American University Washington College of Law, where she was a member of the Moot Court Honor Society and received the ABA National Appellate Advocacy Competition Award for National Best Brief. She holds a B.S. from Frostburg State University. She is admitted before the U.S. Tax Court and in the District of Columbia and Maryland.

• Recognition & Leadership

Meghan was named “Lawyer of the Year” in Nonprofit/Charities Law for Washington, D.C. by The Best Lawyers in America (2025) and has been recognized as a “Best Lawyer” in Nonprofit/Charities Law by the same publication (2024–2026). She was named in The Legal 500 US for Nonprofit and Tax Exempt Organizations (2025). During her government service, she received the Commissioner’s Award for her work on the Achieving a Better Life Experience (ABLE) Act 529A and Certified Professional Employer Organization (CPEO) Implementation Team (May 2017) and the Distinguished Service Award from Tax Exempt and Government Entities (January 2018). In 2026, she was elected a Fellow of the American College of Tax Counsel.

• Professional Involvement

Meghan serves as Vice Chair of the Exempt Organizations Committee of the American Bar Association Section of Taxation, and was formerly Vice Chair for Legislative Developments within that committee. She is an Associate Member of the Exempt Organizations Technical Resource Panel of the American Institute of Certified Public Accountants (AICPA) and a member of the American Bar Association. A frequent speaker at national industry institutes, seminars, and conferences on legal issues affecting nonprofits and tax-exempt organizations, her recent engagements include the AICPA Not-for-Profit Industry Conference, Georgetown Law’s Conference on Representing & Managing Tax-Exempt Organizations, the TEGE Annual Exempt Organizations Update and Meeting, the DC Bar’s Annual Tax Conference, and Clark Nuber’s Western Philanthropy Conference.

• Experience

Meghan brings more than 10 years of IRS experience to her practice. During her time at the IRS, she served as senior technical advisor to the director of exempt organizations, advising on all matters related to nonprofits and tax-exempt organizations — including overhauling the application process and enhancing the data-driven approach to examinations — and collaborating with the IRS Chief Counsel and the Treasury Department on the development of regulations and guidance on donor-advised funds, supporting organizations, and political campaign intervention activities. She worked closely with the IRS Division Counsel and the U.S. Department of Justice on exempt organization litigation. Prior to that role, she addressed a wide range of public-sector issues including disaster relief, unrelated business income tax (UBIT), excess benefit transactions, charter and private schools, and environmental concerns. As a Presidential Management Fellow, she served as a special attorney in the Civil Appellate Section of the Tax Division at the Department of Justice, handling a variety of appellate tax litigation issues. She joined Loeb & Loeb as a partner in its Nonprofits and Tax-Exempt Organizations practice in 2024.

 

Susanne Sachsman Grooms, Esq., Partner | Cooley

Susanne Sachsman Grooms is a Partner at Cooley LLP, where she leads the firm’s bipartisan congressional investigations practice. A former federal prosecutor and one of the nation’s leaders in congressional investigations, her practice focuses on helping clients navigate high-stakes, complex investigations that potentially involve multiple federal and state agencies, Congress, and regulatory authorities, as well as significant reputational concerns. Her record of leading hundreds of congressional investigations from inside the government gives her a leading edge in assisting clients with congressional investigations, other government and regulatory investigations, internal investigations, and crisis management. She provides counsel and advice in support of and during matters before Congress, having assisted clients in front of investigatory committees and in responding to individual member requests in both the House and Senate, and she has prepared numerous company executives for public testimony in inquiries around the globe.

• Education & Credentials

Susanne earned her J.D. from Harvard Law School and her B.A., cum laude, from Yale University. She is admitted to practice in New York and the District of Columbia.

• Recognition & Leadership

Susanne is ranked by Chambers USA in Band 1 for Government Relations: Congressional Investigations — Nationwide (2023–2025) and was named to Lawdragon’s 500 Leading Litigators in America (2026). She is recognized in The Legal 500 US for Corporate Investigations and White-Collar Criminal Defense (2025), as a Future Star by Benchmark Litigation, among the Most Influential People in Washington by Washingtonian magazine, and among Lawdragon’s 500 Leading Plaintiff Employment & Civil Rights Lawyers. During her government service she received the Tax Division Outstanding Attorney Award (2005) and the Tax Division Special Act or Service Award (2006) from the U.S. Department of Justice.

• Professional Involvement

Susanne teaches Congressional Investigations at the Georgetown University Law Center and is a frequent speaker on matters related to congressional oversight and investigations. She has been an invited speaker at events organized by the American Bar Association, the New York City Bar Association, the University of Pittsburgh Institute of Politics, and the Dick Thornburgh Forum for Law and Public Policy, and she serves on Law360’s Massachusetts editorial advisory board (2025).

• Experience

Susanne began her career as a trial attorney in the Tax Division of the U.S. Department of Justice, where she was a member of the Attorney General’s Honors Program. From 2008 to 2010, she served in a number of roles at the Internal Revenue Service, including as attorney adviser to the deputy commissioner for services and enforcement and as senior counsel to the chief of criminal investigation. In 2010, she was detailed to the White House, where she served as deputy associate counsel in the Office of Presidential Personnel, vetting presidential appointments and nominations and advising on tax compliance and other legal matters. She joined the U.S. House Committee on Oversight and Government Reform — the principal investigative committee of the U.S. House of Representatives — as counsel under Chairman Henry A. Waxman, and advanced into senior leadership, supervising and conducting hundreds of congressional hearings and investigations and leading the committee’s investigative staff from 2011 to 2021. As deputy staff director and chief counsel for then-Chairwoman Carolyn Maloney and her predecessor Chairman Elijah E. Cummings, she oversaw a team of more than 70 attorneys, investigators, and communications and support staff on hundreds of high-profile investigations, and she served on the investigatory and Senate trial teams for both impeachments of Donald J. Trump. Since February 2024, she has led Cooley’s congressional investigations practice, where her representations include advising Fortune 500 companies, financial institutions, universities, media organizations, and senior executives in connection with investigations and public testimony before congressional committees in the U.S. and abroad.

 

Casey A. Lothamer, Esq., Senior Counsel | Loeb & Loeb

Casey A. Lothamer is Senior Counsel at Loeb & Loeb LLP in Washington, DC, where he advises nonprofits and tax-exempt organizations across the full spectrum of federal tax and regulatory matters, ranging from organizational structuring and tax-exemption issues to governance, compliance, IRS controversy and operational matters. Drawing on nearly 20 years of experience within the IRS Tax Exempt & Government Entities Division Counsel (TEGEDC), he guides clients through IRS examinations, determinations, compliance matters, audits, investigations and tax controversy proceedings. Casey advises public charities, private foundations, social welfare organizations and international nonprofits with U.S. affiliates on governance, operational structuring and compliance with federal tax requirements applicable to exempt organizations. He assists with tax-exempt status applications, private letter ruling requests and other agency submissions, as well as excise tax matters affecting private foundations and the implementation of compliant charitable programs. He also conducts mock audits and compliance assessments to help organizations identify potential issues and strengthen their preparedness ahead of examinations, represents clients in tax controversy and enforcement matters — including matters before the U.S. Tax Court — and counsels clients on regulatory developments affecting exempt organizations while engaging with government officials on Treasury regulations and IRS guidance.

• Education & Credentials

Casey earned an LL.M. in Taxation from Georgetown University Law Center and his J.D. from the University of Pittsburgh School of Law, where he served as Founder and Executive Editor of the Pittsburgh Tax Review. He holds a B.S. from the University of Central Florida. He is admitted to practice before the U.S. Supreme Court and the U.S. Tax Court and is admitted only in Maryland.

• Recognition & Leadership

Casey served as a Former Adjunct Professor at the University of Baltimore School of Law from 2024 to 2025.

• Experience

Before joining Loeb, Casey served for nearly two decades across a progression of senior roles within the TEGEDC of the Office of Chief Counsel at the IRS, including as senior level counsel and area counsel, where he was instrumental in shaping and advancing the IRS’ legal positions on complex exempt organization matters. While at the TEGEDC, he led and supervised significant, high-stakes litigation at both the trial and appellate levels and served as the primary technical authority for exempt organization issues within his branch. He played a central role in reviewing, approving and issuing guidance on the federal tax treatment of sophisticated transactions involving tax-exempt entities, including regulations with nationwide impact, and oversaw technical advice provided to both the public and the IRS. He also reviewed defense submissions to the U.S. Department of Justice in declaratory judgment actions brought by tax-exempt organizations.

 

Christopher Slade, Esq., Partner | Aird & Berlis

Christopher Slade is a Partner at Aird & Berlis LLP, based in Toronto, and a member of the firm’s Tax Group and Tax Controversy/Tax Litigation Group. Chris is a skilled advocate with extensive experience advising on domestic and international tax controversy and litigation matters, having successfully represented a wide range of clients—including multinational corporations, financial institutions, pension funds, and ultra high net worth individuals—and he routinely acts on high-value and complex cases. His strategic approach positions clients for effective negotiation with the tax authorities, with the objective of obtaining favourable results efficiently and avoiding litigation when possible. In addition to handling tax litigation matters, his practice includes advising clients throughout the audit process, remediation of tax compliance errors and making disclosures under the Voluntary Disclosures Program, obtaining interest and penalty relief and other discretionary remedies, and challenging collection and other administrative action taken by the tax authorities, particularly in the cross-border context.

• Education & Credentials

Chris earned his J.D. (Dean’s Silver Scholar) from Queen’s University (2008), a B.Sc. in Physics, with Distinction, from Western University (2004), and an Artist’s Diploma in Piano Performance, with Distinction, from Western University (2004), and has completed the CPA In-Depth Tax Course, Parts I and II. He was called to the Ontario bar in 2009.

• Recognition & Leadership

Chris is highly regarded in domestic and international tax controversy and litigation. He is recognized by Chambers and Partners as a leading lawyer in the area of Tax Litigation—praised for being “extremely thorough and prepared” and “very calm in his approach to clients’ situations”—is featured in The Canadian Legal Lexpert Directory as a leading lawyer in Litigation–Corporate Tax, and has been included since 2019 in the International Tax Review’s World Tax Guide as a Highly Regarded practitioner in Tax Controversy, including recognition as a 2024 and 2025 ITR World Tax Leader. He has an exceptional track record, having successfully resolved the majority of his cases by consent judgment or at the administrative appeals level.

• Professional Involvement

Chris is a co-author of the Chambers Tax Controversy Global Practice Guide (Canada Chapter) for multiple years (2023–2025) and the accompanying Canada: Trends and Developments article, and has published numerous articles on a variety of tax issues in professional legal journals, including Tax Litigation and Corporate Finance (Federated Press), Tax Profile (Wolters Kluwer), STEP Inside, and the Ontario Tax Conference papers of the Canadian Tax Foundation, addressing topics such as solicitor-client privilege, equitable remedies after Collins Family Trust, the Minister’s power to compel production, voluntary disclosure of offshore holdings, trust residence, rectification, beneficial ownership in Canada’s tax treaties, and Part XIII withholding. He has presented at numerous conferences and events for tax executives and practitioners in Canada and internationally.

• Experience

Chris has extensive experience advising on domestic and international tax controversy and litigation matters, representing multinational corporations, financial institutions, pension funds, and ultra high net worth individuals on complex, high-value cases. Beyond litigation, he advises clients through the audit process, remediates tax compliance errors and makes Voluntary Disclosures Program disclosures, obtains interest and penalty relief and other discretionary remedies, and challenges collection and other administrative action by tax authorities, particularly in the cross-border context, and he collaborates with other members of the Tax Group on transactional and tax advisory matters. Early in his legal career, Chris completed a judicial clerkship at the Tax Court of Canada. Prior to joining Aird & Berlis, he was a senior partner at a national law firm affiliated with one of the Big 4 accounting firms, where he co-led the affiliated firm’s tax litigation practice in Toronto.

 

Amanda P. Swartz, Esq., Of Counsel | Meadows, Collier, Reed, Cousins, Crouch & Ungerman

Amanda P. Swartz is an attorney at Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P., a Dallas-based firm (headquartered at 901 Main Street, Dallas) whose origins are in tax planning and tax litigation. She is a tax attorney with broad tax litigation, controversy, and transactional experience. As part of the firm’s tax practice, she represents taxpayers in civil and administrative tax controversies, including matters before the IRS Examination and Appeals Divisions and, when disputes cannot be resolved administratively, in litigation.

• Amanda P. Swartz

Amanda studied law at New York University School of Law and holds an LL.M. in Taxation. Based on her own professional updates, she has passed the Georgia Bar examination.

• Amanda P. Swartz

Amanda speaks on tax topics, including criminal tax—for example, presenting at the Texas A&M University School of Law Tax Dispute Resolution Clinic.

• Amanda P. Swartz

Amanda’s practice encompasses tax litigation, tax controversy, and transactional tax matters. Within Meadows Collier’s litigation practice, the firm defends clients in investigations, litigation, and other civil, criminal, and administrative controversies with governmental agencies, including disputed individual, partnership, corporate, and estate tax issues, while its transactional practice addresses the tax and regulatory consequences of business, corporate, real estate, and estate planning transactions.

 

J. Clark Armitage, Esq., Member | Caplin & Drysdale, Chartered

J. Clark Armitage is a Member at Caplin & Drysdale, Chartered, based in the firm’s Washington, D.C. office, and an experienced international tax lawyer with a focus on transfer pricing. Mr. Armitage’s core practice is advising multinational corporations from a wide range of industries on transfer pricing matters, including planning, audits and appeals, advance pricing agreements (APAs), and Mutual Agreement Procedures (MAPs), and he has a particularly strong background in APAs, having served eight years in the IRS Advance Pricing Agreement Program, including as Deputy Director from 2008 to 2010. A significant portion of his practice involves helping clients navigate the U.S. federal income tax implications, under sections 933 and 937, of bona fide Puerto Rican residency and status under Puerto Rico Act 20, Act 22, Act 60, and Act 73, including residency, transfer pricing, sourcing, and structuring advice. He also advises clients on other U.S. international and domestic tax issues, such as eligibility for section 1202 (qualified small business stock), sourcing of income and expense, U.S. trade or business issues, S corporation status, partnership tax issues, expatriation, planning for GILTI (now the “net CFC tested income regime” or NCTI), and PFIC planning.

• Education & Credentials

Mr. Armitage earned his J.D. from The George Washington University Law School (1990) and his B.A. from American University (1987). He is admitted to practice in the District of Columbia and Maryland.

• Recognition & Leadership

Mr. Armitage has been recognized by The Legal 500 as Recommended (2014–2023) and as part of its Top-Tier Firm for Tax–US Taxes–Contentious (2014–present) and International Tax Team of the Year (2014 and 2015); by Best Lawyers in America (2019–present); by Acquisition International as Best for International Transfer Pricing Issues–Washington, D.C. (2015); and by ITR World Transfer Pricing as Highly Regarded (2020). He served as President of Caplin & Drysdale (named in 2018). During his eight years with the IRS APA Program, he served as team leader, branch chief, and industry coordinator for three separate groups, as well as Deputy Director (2008–2010).

• Professional Involvement

Mr. Armitage is a member of the District of Columbia Bar Association, the Maryland Bar Association, and the U.S. Council for International Business, and formerly taught “Introduction to Transfer Pricing” as an adjunct professor for the Georgetown University Law Center. He is a prolific speaker and author on transfer pricing and international tax. His frequent speaking engagements span the NYU Tax Controversy Forum, the NABE Transfer Pricing Symposium, TP Minds Americas, the USD Transfer Pricing Symposium, the IFA USA Branch, the GW/IRS Annual Institute on Current Issues in International Taxation, and numerous Strafford and ABA programs, addressing APAs and MAPs, the Coca-Cola and Medtronic cases, periodic adjustments, Puerto Rico residency tax incentives, and the evolving U.S. transfer pricing landscape. His extensive publications include articles in Tax Notes, the IBFD International Transfer Pricing Journal, Bloomberg Tax, and Financier Worldwide, as well as the Bloomberg BNA Tax Management Portfolio “Transfer Pricing: Rules and Practice in Selected Countries (H-1),” and he is frequently quoted by Bloomberg Law, Law360, Tax Notes, The New York Times, and POLITICO on transfer pricing and international tax developments.

• Experience

During his tenure at Caplin & Drysdale, Mr. Armitage has worked on numerous APA and MAP cases, IRS audits and Appeals, other tax controversy work, and tax planning for corporate and high-net-worth individual clients. During his eight years with the IRS APA Program, he served as team leader, branch chief, and industry coordinator for three separate groups (Financial Products; Pharmaceuticals and Medical Devices; and Auto and Auto Parts), as well as Deputy Director. As a frontline supervisor, he reviewed APAs developed by other IRS teams and coordinated development of cases in the industry coordination groups, and he had Program-wide responsibility for reviewing cases, coordinating technical issues with other branches of the Office of the Associate Chief Counsel (International), and ensuring consistent treatment of substantive and procedural issues across the Program. His APA Program contributions were bolstered by a detail as a manager for the U.S. Competent Authority’s Office of Tax Treaty, where he supervised and reviewed Competent Authority analysts responsible for Canadian cases, and in 2008 he served as the APA Program’s representative to the IRS Transfer Pricing Task Force. Before joining the APA Program, Mr. Armitage was senior vice president for a venture capital fund management company, served in London on the U.S. Tax Desk of a major accounting firm, and worked with several leading law firms.

 

Amie Colwell Breslow, Esq., Of Counsel | Jones Day

Amie Colwell Breslow is Of Counsel in the Tax practice at Jones Day, based in the firm’s Washington office. She practices across a broad range of U.S. federal tax matters, including cross-border mergers, acquisitions, spin-offs, and other divisive strategies and restructurings, and certain specialized tax issues such as excise taxes and blockchain and digital assets—including conducting digital currency transactions and conversions, token offerings, and different investment and entity structures. Amie has extensive experience working with large multinational companies on managing and executing complex, multi-step reorganizations and divestitures, developing workable policies at an industry-wide level in response to global economic policy initiatives, and changes in foreign tax and corporate law. As a former in-house tax counsel and government attorney, she blends substantive tax knowledge with an understanding of corporate objectives and first-hand insights on the guidance and publications process.

• Education & Credentials

Amie earned her J.D. from Brooklyn Law School (1998), a B.S. in Accounting from Syracuse University (1995), and a Certificate of Legal Studies in Anti-Corruption Law from American University (2018). She is admitted to practice in the District of Columbia and New York.

• Recognition & Leadership

Amie is a Fellow of the American College of Tax Counsel. She is involved with the International Fiscal Association’s Women in IFA Network (WIN), and within the ABA Tax Section’s Foreign Activities of U.S. Taxpayers (FAUST) Committee served as Chair (2021–2023) and Vice Chair (2019–2021). She received the PepsiCo Chairman’s Award (2005). Her government service includes serving as an Attorney-Advisor in the Office of Associate Chief Counsel (Corporate) at the Internal Revenue Service (2009–2015).

• Professional Involvement

Amie is an American College of Tax Counsel Fellow and a member of the Tax Coalition, the ABA Section of Taxation (Corporate [officer] and Foreign Activities of U.S. Taxpayers [FAUST] [chair 2021–2023, vice chair 2019–2021] Committees), and the International Fiscal Association (IFA). She is a frequent speaker at the ABA, IBA, IFA, the GW/IRS Conference, the DC Bar, the Federal Bar, the International Tax Institute, and TEI on a multitude of transaction topics, including cross-border 304 transactions, tax-free and taxable M&A transactions, and digital currency. She is co-author of “Corporate Separations,” BNA Portfolio 776 (Bloomberg Tax, March 2025), and has authored numerous Jones Day commentaries and alerts on topics including the 1% corporate stock buyback tax, Section 355 spin-off regulations, qualified small business stock, crypto regulation, and clean energy tax credits. Her recent speaking engagements span the ABA May and Midyear Tax Meetings, the IFA USA Branch Annual Conference, the NYU Institute on Federal Taxation, PLI’s corporate tax strategies program, Strafford, the GW/IRS Institute on Current Issues in International Taxation, and the London Finance and Capital Markets Conference, addressing Section 355 guidance, previously taxed earnings and profits (PTEP) regulations, cross-border combinations, the BEAT, and digital assets.

• Experience

Amie has extensive experience advising large multinational companies on complex, multi-step reorganizations and divestitures. Prior to joining Jones Day, she was a Senior Tax Counsel at General Electric, and before joining GE she served in the IRS Office of Associate Chief Counsel (Corporate), where she worked on published guidance, controversy matters, private letter rulings, and tax policy matters concerning corporate and international tax transactions and issues. At Jones Day, her representative transactions include advising Verint Systems on its $2 billion take-private by Thoma Bravo, The Sherwin-Williams Company on its $1.15 billion acquisition of BASF’s Brazilian architectural paints business, KKR in connection with OneStream’s $490 million IPO and Up-C reorganization, Monster Beverage on its $330 million acquisition of CANarchy Craft Brewery Collective, and Signature Aviation on numerous acquisitions and divestitures. Prior to joining Jones Day, she represented General Electric Company as lead tax counsel in numerous transactions, including the approximately $21 billion tax-free split-off of Synchrony Financial and the $1.65 billion acquisition of LM Wind Power, and executed multiple restructurings including the carve-out of GE Oil & Gas assets for the joint venture with Baker Hughes and the separation of GE industrial and GE Capital financial assets—work that resulted in GE Capital becoming the first financial institution to shed its designation as systemically important to the financial system—and the integration of Alstom Power and Grid into GE Power.

 

Michael Sardar, Esq., Partner | Kostelanetz

Michael Sardar is a Partner at Kostelanetz LLP, based in New York City, with extensive experience on a wide range of tax controversy and white-collar criminal defense matters. Michael 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. He represents and advises taxpayers facing audits and investigations of noncompliance with IRS foreign bank and asset reporting requirements, and has a great deal of experience representing corporate and individual taxpayers making voluntary disclosures of unreported income to the IRS and state tax authorities, having enabled the repatriation of over half a billion dollars of offshore assets through the IRS Offshore Voluntary Disclosure Program, the Streamlined Compliance Procedures, and the IRS’s current Voluntary Disclosure Practice.

• Education & Credentials

Michael graduated summa cum laude from Baruch College in 2004 with a bachelor’s degree in Business Administration (BBA in Marketing Management) and received his law degree from Cornell Law School in 2007. He is admitted to practice in New York State and before the U.S. District Courts for the Southern and Eastern Districts of New York and the United States Tax Court.

• Recognition & Leadership

Michael has been recognized by Best Lawyers for Litigation and Controversy–Tax in New York and by Super Lawyers for Tax in New York. He joined Kostelanetz LLP in 2009 and was named partner in January 2019.

• Professional Involvement

Michael is Co-Chair of the Federal Bar Association (FBA) Section on Taxation, New York Chapter, and 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. Michael lectures and writes frequently on tax controversy topics, including foreign asset reporting and noncompliance, with recent publications including “The Scope of Personal Liability for Trust Fund Tax in the State of New York” (June 2026) and “Claiming Residency in Puerto Rico May Spur More State-Based Tax Audits” (April 2025), and recent and upcoming speaking engagements including the ABA Midyear Tax Meeting, the IRS Representation Conference, and the firm’s Annual Tax Controversy Seminar & BBQ.

• Experience

Michael represents clients in criminal tax investigations, including those involving allegations of willful nondisclosure of foreign bank accounts and under-reporting of income, as well as various white-collar criminal matters such as customs fraud and bank fraud, and he advises clients in connection with internal investigations regarding corporate and entity noncompliance. He represents taxpayers in New York State and City residency audits and investigations, including those involving the sourcing of income for multi-state taxpayers, and has represented clients in tax investigations conducted by the New York State Attorney General’s Office. He has advised many nonprofit organizations on federal and state tax issues, including general tax exemption and Unrelated Business Income Tax (UBIT), and represents clients in gift and estate tax audits challenging the IRS’s valuation of gifts and bequests. Prior to joining Kostelanetz, Michael was an attorney with Heller Ehrman LLP, where his practice focused on transactional tax matters. Among his representative matters, he convinced the DOJ Tax Division to discontinue a criminal investigation relating to a client’s purported failure to report over $50 million of foreign assets on income tax returns and FBARs; represented a telecom executive who disclosed $50 million in previously unreported foreign bank accounts and convinced the IRS that the noncompliance was not willful, saving the client more than $10 million in penalties; secured non-jail sentences for clients facing significant prison exposure under the U.S. Sentencing Guidelines in fraud matters; obtained the cancellation of an entire “responsible officer” withholding tax assessment despite time-barred statutory remedies; secured innocent spouse relief for a client before the IRS and New York State; and obtained credit for $3 million in taxes withheld on a taxpayer’s foreign account that the IRS had previously denied.

 

Caitlin R. Tharp, Esq. Partner | Steptoe

Caitlin R. Tharp is a Partner at Steptoe LLP, based in the firm’s Washington, DC office. Caitlin’s multidisciplinary practice focuses on tax controversy, ERISA, and employee benefits, covering both litigation and counseling in those areas. She has more than a decade of experience handling disputes with tax authorities, both at the administrative level and in litigation, having represented clients in IRS examinations, achieved full IRS concessions at IRS Appeals, and resolved taxpayers’ administrative delays with the IRS. Her litigation experience spans all forums for tax disputes—the Tax Court, the Court of Federal Claims, various appellate courts, and federal district courts across the country—and has included challenges to regulations and sub regulatory guidance, the economic substance doctrine, excise taxes, alternative energy tax credits, captive insurance, the employee retention credit, and cross-border transactions.

• Education & Credentials

Caitlin earned her LL.M. in Taxation, with distinction, from Georgetown University Law Center (2016), her J.D. from Georgetown University Law Center (2015), and her B.A. from Stanford University (2012). She is admitted to practice in the District of Columbia and Virginia, and before the U.S. Tax Court, the U.S. District Court for the District of Columbia, the U.S. Courts of Appeals for the District of Columbia and Federal Circuits, and the U.S. Court of Federal Claims.

• Recognition & Leadership

Caitlin has been recognized by The Best Lawyers in America as “Ones to Watch” for Tax Law and Litigation & Controversy–Tax (2026) and by Super Lawyers as a “Rising Star” in Tax Law (2024–2025). She was named a 2023–24 John S. Nolan Fellow by the ABA Tax Section, a distinction awarded to lawyers who have demonstrated leadership qualities and active involvement in the Section, and was elevated to Partner in Steptoe’s 2026 class.

• Professional Involvement

Caitlin is a former Vice Chair of the Tax Practice and Technology Committee of the ABA’s Tax Section, an Advisory Committee Member for the Federal Bar Association’s Insurance Tax Seminar, and a member of the Nominating Committee of the ABA Section of Taxation. A frequent speaker and writer on emerging issues in tax controversy and practice—including the use of artificial intelligence both by practitioners and by the IRS in tax enforcement—she has presented at the NYU Tax Controversy Forum, PLI’s Tax Controversy program, the IBA’s London Finance and Capital Markets Conference, the DC Bar Tax Conference, the Southern Federal Tax Institute, and numerous ABA Section of Taxation meetings, on topics ranging from AI ethics under Circular 230 and “taxing the metaverse” to challenging penalties under Section 6751(b). Her publications include client alerts and articles on the economic substance doctrine, IRS listing notices, the employee retention credit, ESOP/ERISA developments, and exempt-organization tax issues, and she has been quoted in Tax Notes and Law360 on tax professionals’ adoption of AI.

• Experience

Caitlin’s tax controversy experience spans administrative proceedings and litigation in all forums. Her representative matters include serving as lead counsel in a Court of Federal Claims refund action involving foreign tax credits and the high-tax kick-out exception; winning a refund action as trial counsel for a principal in a contract manufacturing arrangement concerning the Section 199 domestic production activities deduction (Meredith Corp. v. United States); achieving a 99% IRS concession in an alleged ESOP prohibited transaction case in Tax Court; serving as trial and appellate counsel in a Court of Federal Claims case involving the IRS’s assertion of transferee liability (Dillon Trust Co. LLC v. United States); serving as trial and appellate counsel in a Tax Court case challenging several million dollars of Section 45K nonconventional fuel credits for landfill gas production (Green Gas Delaware Statutory Trust v. Commissioner, aff’d D.C. Cir.); and winning 100% IRS concessions for a pharmaceutical company, an energy company, and a healthcare company in IRS Appeals and Collection Due Process matters. Her ERISA experience includes litigating alleged breaches of fiduciary responsibility, prohibited transactions, and withdrawal liability, with a particular focus on the valuation of closely held businesses arising from her defense of clients against allegations of inadequate consideration in ESOP transactions, and she also counsels employee benefit funds on plan administration and compliance with ERISA and Internal Revenue Code requirements.

 

Kimberly B. Tyson, Esq., Managing Partner | K. Tyson Law, PLLC

Kimberly Butlak Tyson is the founder of K. Tyson Law, PLLC, based in Matthews, North Carolina. Kim’s tax practice focuses on the tax aspects of charitable giving, civil tax penalties, disputes with the IRS, tax litigation, and litigation support, and she serves clients throughout the U.S. who need help with federal income tax issues. With over 25 years of experience practicing tax law—which began as a student-attorney in a federal tax clinic—Kim has been described as someone who makes the “impossible possible” because of her detailed approach, creative solutions, and strong work ethic. Through K. Tyson Law, PLLC, she brings to the private sector her commitment to serve, her creativity, her work ethic, and more than 20 years of understanding of the inner workings of the IRS and the U.S. Tax Court.

• Education & Credentials

Kim earned her LL.M. in Taxation and a Certificate in Employee Benefits from Georgetown University Law Center, her J.D. from the University of Baltimore School of Law, and her B.S. from Frostburg State University. She is admitted to practice before the North Carolina State Bar and the U.S. Tax Court.

• Recognition & Leadership

Kim is a Fellow of the American College of Tax Counsel. During her IRS service, she was repeatedly recognized for outstanding contributions, including being named “Attorney of the Year” in 2022—a single nationwide award issued to one field attorney by the IRS Office of Chief Counsel, recognizing her work on conservation easement cases and advisory work to IRS exam. Her many other honors include the IRS Office of Fraud Enforcement All-Star Award (2021); Manager of the Year for the IRS Office of Chief Counsel, Litigation & Advisory, Area 2 (2025); the Director’s Award (2015); multiple Special Act Awards (2021–2024); the Treasury Outstanding Litigation Team Award (2022); multiple Outstanding Contribution Team Awards (2020–2022); a Special Merit Award from the IRS Office of Fraud Enforcement (2022); and Commissioner’s Awards from IRS Commissioner Charles Rettig (2020 and 2022). She was promoted to Senior Counsel and Supervisory Attorney during her IRS tenure.

• Professional Involvement

Kim is a member of the Land Trust Alliance, the J. Edgar Murdock Inns of Court, the American Bar Association, the North Carolina Bar Association, and the Mecklenburg County Bar Association, and a Fellow of the American College of Tax Counsel. She founded the NCBA Calendar Call Program and serves as its inaugural administrator; the program provides assistance to taxpayers who cannot afford private counsel and could benefit from a non-IRS person to explain court procedures, the strength of a case, and evidentiary issues. She is an active author, with recent publications including “How the Discoverability of AI Conversations Could Affect Tax Cases” (Tax Notes: Procedurally Taxing blog, 2026), “Determining Material Adviser Status for Syndicated Conservation Easements” (Tax Notes Federal, 2026), and “Recognition by the Tax Court that Domestic Abuse Permeates Socioeconomic Strata” (NCBA Blog, 2026).

• Experience

Kim served for two years as a U.S. Tax Court law clerk and subsequently practiced as an attorney in a multinational law firm, advising on employee benefits, tax, and corporate matters. In 2006, she joined the IRS Office of Chief Counsel, where she was promoted to Senior Counsel and Supervisory Attorney. In her cases, the amounts at issue ranged from several thousand dollars to more than a billion dollars; she successfully litigated cases on behalf of the IRS in the U.S. Tax Court and advised on significant refund cases litigated by the U.S. Department of Justice in U.S. District Courts and the U.S. Court of Federal Claims. For over a decade, she served as a “subject matter expert” for civil tax penalties within the IRS Office of Chief Counsel for the IRS’s Large Business & International Division, and for more than five years she advised revenue agents and attorneys nationwide on tax issues associated with charitable giving and advised IRS and Office of Chief Counsel leadership on those issues. She also taught scores of training sessions to revenue agents and IRS attorneys nationwide on civil penalties and conservation easements. She now applies this experience in private practice at K. Tyson Law, PLLC.

 

Conor P. Desmond, Esq., Associate | Caplin & Drysdale, Chartered

Conor P. Desmond is an Associate in the Tax Disputes & Tax Litigation practice group at Caplin & Drysdale, Chartered, based in the firm’s Washington, D.C. office, which he joined in 2024. Mr. Desmond’s practice centers on assisting individuals and corporations in matters relating to compliance with their U.S. tax obligations. He advises clients on a broad range of tax issues, with a particular focus on assisting individuals, trusts, partnerships, and corporate entities in responding to and defending against civil IRS audits and examinations, as well as actions in federal court such as refunds and other matters.

• Education & Credentials

Mr. Desmond earned his J.D. and his M.P.P. (Master of Public Policy) from Loyola University Chicago in 2015, and his B.S. from the University of Illinois in 2009. He is admitted to practice in the District of Columbia and Illinois, and before the United States Supreme Court, the U.S. Court of Federal Claims, and the U.S. Tax Court.

• Recognition & Leadership

In 2024, the American Bar Association Young Lawyers Division recognized Mr. Desmond as an On the Rise – Top 40 Young Lawyer (National Top 40 Under 40). He is an American Bar Foundation Fellow. During his government service, he received the Department of Justice Assistant Attorney General Award for Training (2023), the DOJ Outstanding Attorney Award three years running (2022–2024), a DOJ Commendation (2021), and the Chicago Volunteer Legal Services Award for Providing Equal Access to Justice. At the DOJ Tax Division, he handled one of the most complex dockets in Civil Trial Southern.

• Professional Involvement

Mr. Desmond serves as Vice-Chair of the ABA Section of Taxation’s Tax Practice and Technology Committee and is a member of the American Bar Association’s Tax Section, Young Lawyers Section, and Business Law Section, including the Civil Penalties Subcommittee of the Civil and Criminal Tax Penalties Committee. He is a frequent speaker and author on tax discovery, electronic discovery, and the ethics of using artificial intelligence in tax practice, with recent and upcoming engagements including co-leading the Tax Section Task Force on Artificial Intelligence Town Hall and moderating AI and electronic discovery panels at the ABA May Tax Meeting, and presenting on AI ethics at the FBA Insurance Tax Seminar and the ABA Criminal Tax Fraud and Tax Controversy Conference. His publications include “Discovery in Tax Litigation — Document Processing and Review” (Tax Analysts, 2025), “Discovery in Tax Litigation — Duty to Preserve” (Tax Notes Federal, 2025), “Law Firm Client Lists and Attorney-Client Privilege” (2025), and “A Guide for Attorneys Litigating Against Self-Represented Individuals” (American Bar Association, 2024).
He is skilled in managing Electronically Stored Information (ESI) discovery and in developing an understanding of generative AI technologies.

• Experience

Prior to joining Caplin & Drysdale, Mr. Desmond served as a Trial Attorney for the U.S. Department of Justice, Tax Division (2019–2024), where he led multiple teams presenting arguments in both bench and trial matters, devising strategy, drafting discovery, reviewing settlement offers, solving problems as they arose, and reaching successful conclusions; he handled one of the most complex dockets in Civil Trial Southern and was named outstanding attorney three years in a row. Before that, he served as an Assistant Attorney General in the Office of the Illinois Attorney General (2018–2019). While at Loyola University Chicago School of Law, he served as Editor in Chief of the Loyola University Chicago Public Interest Law Reporter, was a semi-finalist member of Loyola’s Chicago Bar Association Moot Court Team, and was a practicing student attorney with the Health Justice Project / Chicago Volunteer Legal Services while simultaneously earning his master’s degree in public policy.

 

Jason B. Grover, Esq., Counsel | Latham & Watkins

Jason B. Grover is Counsel in the Tax practice at Latham & Watkins LLP, based in the firm’s Chicago office. Jason resolves high-stakes disputes with the IRS on behalf of clients facing intractable tax controversies across a wide range of substantive issues. He pursues strategic solutions for taxpayers—including the world’s largest corporations, emerging companies, and high-net-worth individuals—in all stages of federal tax controversies, navigating complex audits (including those involving potential criminal exposure), contentious IRS Independent Office of Appeals conferences, and litigation before the U.S. Tax Court, the U.S. Court of Federal Claims, and U.S. district courts. He helps clients secure the optimal outcome of a dispute, whether through creative IRS settlement or dogged litigation, and leverages particular knowledge of the procedural and substantive aspects of partnership audits—both under the legacy TEFRA regime and under the new BBA rules—to guide clients in this evolving landscape.

• Education & Credentials

Jason earned his J.D., cum laude, from Northwestern University School of Law (2012), his M.A. from Northwestern University (2009), and his B.A., cum laude, from Princeton University (2005). He is admitted to practice in Illinois and the District of Columbia.

• Recognition & Leadership

A recognized thought leader, Jason frequently writes on tax matters and speaks before the American Bar Association, the Federal Bar Association, and other professional associations. He was named Counsel at Latham & Watkins in the firm’s October 2022 class.

• Professional Involvement

Jason frequently writes and speaks on tax matters before the American Bar Association, the Federal Bar Association, and other professional associations. His authored client alerts and articles address IRS use of artificial intelligence and increased funding in large partnership audits (“IRS Launches New Large Partnership Audits, Relying on AI and Increased Funding,” 2024; “New IRS Unit Leverages AI to Step Up Partnership Audits,” 2024) and syndicated conservation easements (“US Tax Court Voids Penalties Affecting Syndicated Conservation Easements,” 2022). His practice spans International Tax, Tax, Tax Controversy, White Collar Defense & Investigations, Tax-Exempt Organizations, and Digital Assets & Web3, with industry focuses in fintech and technology. He maintains an active pro bono practice through which he serves individual low-income taxpayers.

• Experience

Jason represents the world’s largest corporations, emerging companies, and high-net-worth individuals in all stages of federal tax controversies, including complex audits (some involving potential criminal exposure), IRS Independent Office of Appeals conferences, and litigation before the U.S. Tax Court, the U.S. Court of Federal Claims, and U.S. district courts. He has particular knowledge of the procedural and substantive aspects of partnership audits under both the legacy TEFRA regime and the new BBA rules. Before joining Latham, Jason worked in another global law firm’s tax controversy practice.

 

Gilbert S. Rothenberg, Esq., Adjunct Professor | American University

Gilbert Rothenberg is an Adjunct Professor at American University Washington College of Law (WCL), where he teaches in the area of tax law. A career federal tax litigator, Mr. Rothenberg worked in the U.S. Department of Justice’s Tax Division for his entire career, ultimately serving as Chief of the Tax Division’s Appellate Section. For more than 35 years, he has taught courses at WCL in individual, corporate, and partnership income tax.

• Education & Credentials

Mr. Rothenberg earned his B.A. in Economics from the University of Pennsylvania (1971), his J.D. from American University’s Washington College of Law (1975), and his LL.M. in Taxation from Georgetown University Law Center (1979).

• Recognition & Leadership

Mr. Rothenberg was profiled in the Winter 2010 issue of the ABA Section of Taxation NewsQuarterly. During his DOJ career, he handled landmark appellate matters including the Tufts and Diedrich cases, and more recently argued the Murphy and Cohen cases before the D.C. Circuit (the latter en banc). For the last 15 years of his tenure, until his retirement in November 2019, he served as Chief of the Tax Division’s Appellate Section, overseeing a staff of approximately 50 attorneys and support personnel.

• Professional Involvement

Mr. Rothenberg currently serves as Associate Editor-in-Chief of The Tax Lawyer, a law review publication of the ABA’s Tax Section. He is a frequent speaker and panel member at federal tax conferences. His publications include an article on tax deficiency procedures in The Virginia Tax Review—later reprinted in abbreviated form in The Monthly Digest of Tax Articles—and a chapter in the ABA’s 2009 publication Careers in Tax Law. Beyond WCL, he has taught tax courses at George Mason University Law School and the University of Maryland Law School, and currently teaches corporate tax (via Zoom) at the University of Pennsylvania Law School.

• Experience

Mr. Rothenberg worked in the Justice Department’s Tax Division for his entire career, starting as a line attorney in the Division’s Appellate Section, where he handled numerous significant matters including the landmark Tufts and Diedrich cases and, more recently, argued the Murphy and Cohen cases before the D.C. Circuit (the latter en banc). For the final 15 years of his tenure, until retiring in November 2019, he served as Chief of the Tax Division’s Appellate Section, overseeing a staff of approximately 50 attorneys and support personnel. Alongside his government service, he has maintained a decades-long teaching career in individual, corporate, and partnership income tax at American University Washington College of Law and other law schools.

 

Sanford J. Boxerman, Esq., Shareholder | Neill Schwerin Boxerman, PC

Sanford “Sandy” J. Boxerman is a Shareholder at Neill Schwerin Boxerman, P.C. in St. Louis. Sandy defends individuals and corporations in white-collar investigations and prosecutions, represents taxpayers in civil and criminal tax matters, and advises participants (and would-be participants) in the digital assets space. From 1991 to 1994, he served as an assistant public defender in the City of St. Louis, where he first-chaired numerous jury and bench trials, including two jury trials in one week. In addition to his active law practice, Sandy teaches the tax fraud prosecutions course in the graduate tax program at the Washington University School of Law, and for many years taught the Legal Environment of Business course at the Washington University Olin Business School.

• Education & Credentials

Sandy earned his J.D., magna cum laude, from Harvard Law School (1988) and his B.S. in Business Administration, with highest honors, from Washington University (1985). He is licensed in Missouri and Illinois, and admitted to practice before the Supreme Court of the United States; the U.S. Courts of Appeals for the Sixth, Seventh, and Eighth Circuits; the U.S. District Courts for the Eastern and Western Districts of Missouri, the Southern and Central Districts of Illinois, and the District of Colorado (and pro hac vice in other courts, including the District Court of the U.S. Virgin Islands); and the U.S. Tax Court. He is also an approved FINRA arbitrator.

• Recognition & Leadership

Sandy is a Fellow of the American College of Tax Counsel. He received the Top Legal Innovation Award (Emerging Practice Areas) for blockchain and cryptocurrency from Missouri Lawyers Media (2018) and was named to “The POWER List” for White-Collar Defense by Missouri Lawyers Weekly (2020–2022). He was named Best Lawyers “Lawyer of the Year” for Litigation and Controversy–Tax in St. Louis (2022) and has been listed in The Best Lawyers in America for Criminal Defense: White-Collar and Litigation and Controversy–Tax in St. Louis (2016–present), in Missouri and Kansas Super Lawyers (2011–present), and as AV Preeminent Peer Review Rated in the Martindale-Hubbell Law Directory.

• Professional Involvement

Sandy is co-chair of the White Collar committee of the Federal Bar Association’s Criminal Section and actively participates in the Tax and Criminal Justice Sections of the American Bar Association, including past service as chair of the St. Louis Regional Subcommittee of the Criminal Justice Section’s White Collar Committee. He serves on the Amicus Committee of the American College of Tax Counsel and is a member of the National Association of Criminal Defense Lawyers, the Missouri Bar, and the Bar Association of Metropolitan St. Louis. He is a prolific speaker and author, with a particular concentration in criminal tax, white-collar defense, and cryptocurrency, presenting frequently at the ABA National Institute on Criminal Tax Fraud, the NYU Tax Controversy Forum, and the New England IRS Representation Conference, and authoring numerous articles in the Journal of Passthrough Entities, the St. Louis Bar Journal, and Criminal Justice on topics including voluntary disclosure, virtual currency, the statute of limitations on fraudulent returns, and federal sentencing. He is actively involved in the broader community, currently serving as immediate past chair of the Professional Society of the Jewish Federation of St. Louis and as a member of the Hadley Township Democratic Club in St. Louis County, and has previously served on the board of directors of Lift for Life Academy, as a coach of the Lafayette High School mock trial team, and as a litigation consultant for the Labadie Environmental Organization; he attends Kol Rinah, where he formerly served on the congregation’s board of directors and as chair of its personnel committee.

• Experience

Sandy began his career as an assistant public defender in the City of St. Louis (1991–1994), first-chairing numerous jury and bench trials. His practice spans white-collar, criminal tax, digital currency, and civil tax matters. In white-collar matters, he has obtained no-action and no-charge resolutions in federal investigations involving hazardous-materials transportation, Anti-Kickback and False Claims Act allegations, qui tam suits, money laundering, opioid prescribing, and health care fraud, and has secured probation or minimal sentences in embezzlement, defense-contractor fraud, and related prosecutions. In criminal tax matters, he has negotiated favorable plea agreements resulting in home-confinement or probation sentences for accountants and business owners charged under 26 U.S.C. § 7206(2), persuaded the government not to pursue charges in several investigations, brought clients into compliance to avoid criminal prosecution, and obtained a reduced FBAR penalty and probation for an international business owner with undeclared foreign assets. In digital currency and blockchain matters, he has represented a bitcoin mining machine retailer in a state securities investigation, guided cryptocurrency-owning taxpayers through return preparation with appropriate disclosures, represented a Money Services Business through Bank Secrecy Act examinations, and represented the founder of a Decentralized Finance protocol in a class action. In civil tax matters, he has represented a major tax-preparation franchisee in a DOJ civil injunction action and related Office of Professional Responsibility proceedings, convinced the IRS to reverse a proposed $400,000 income adjustment from an inaccurate Form 1099, resolved audits with minimal adjustments and no fraud penalties, represented taxpayers in the Offshore Voluntary Disclosure Program and Streamlined Procedures, obtained innocent-spouse relief, and secured a full IRS concession in a U.S. Tax Court case involving capital gains tax on the sale of a home.

 

Rachel Borden, Esq., Counsel | Mayer Brown

Rachel Borden is Counsel in the Tax and Tax Controversy & Litigation practice at Mayer Brown LLP, based in the firm’s Washington DC office. She is an experienced litigator who has handled complex matters at all stages of tax controversy, including IRS audits, administrative appeals, and litigation. Prior to joining Mayer Brown, she was a special trial attorney with the Internal Revenue Service (IRS) Office of Chief Counsel. Rachel has worked on tax matters involving multinational corporations, large partnerships, and high-net-worth individuals, and her experience covers a broad range of subject-matter areas, including transfer pricing, cross-border and treaty issues, valuation disputes, corporate taxation, regulation validity challenges, estate and gift taxation, whistleblower claims, privileges, penalties, and sanctions, spanning industries including pharmaceutical, energy, e-commerce, and financial services.

• Education & Credentials

Rachel earned her J.D. from George Washington University Law School and her A.B., cum laude, from Harvard College. She is admitted to practice in Virginia.

• Recognition & Leadership

She led multiple large trial teams at the IRS Office of Chief Counsel and litigated numerous significant and often precedential cases before the United States Tax Court and, in coordination with the Department of Justice, in U.S. District Courts.

• Professional Involvement

Rachel is a member of the American Bar Association Tax Section and the J. Edgar Murdock American Inn of Court. She has been a speaker at industry events, including the 2026 TEI Midyear Conference and TP Minds West Coast (2025).

• Experience

Rachel has significant litigation experience, including from her time as a special trial attorney with the IRS Office of Chief Counsel. She has led multiple large trial teams and litigated numerous significant and often precedential cases before the United States Tax Court as well as in coordination with the Department of Justice in U.S. District Courts. During her time at the IRS Office of Chief Counsel, she advised IRS audit teams and the Department of Justice on numerous tax compliance issues and technical tax matters and led IRS training on expert witnesses, litigation, discovery, and trial strategy. Her work has encompassed transfer pricing, cross-border and treaty issues, valuation disputes, corporate taxation, regulation validity challenges, estate and gift taxation, whistleblower claims, privileges, penalties, and sanctions, across the pharmaceutical, energy, e-commerce, and financial services industries.

 

Todd Welty, Esq., Partner | Kostelanetz

Todd Welty is a Partner at Kostelanetz LLP, based in the firm’s Atlanta, Georgia office. Todd has extensive experience in resolving civil tax matters at all stages of a tax dispute, including Internal Revenue Service (IRS) examinations, fast-track appeals, administrative appeals, post-appeals mediation and, if necessary, litigation in the U.S. Tax Court, the U.S. Court of Federal Claims, U.S. district courts, and U.S. Courts of Appeal. The vast majority of his cases are resolved administratively and without becoming public, though litigation is sometimes necessary. A seasoned trial lawyer, Todd has a track record of winning difficult cases; Chambers describes him as an “excellent trial lawyer” who is “very effective” at handling tax disputes, and as a “go-to attorney for bet-the-company matters involving the IRS.”

• Education & Credentials

Todd earned his B.A. from West Texas State University (1990) and his J.D. from SMU Dedman School of Law (1993). He is admitted to practice in the District of Columbia (2018), Georgia (2020), and Texas (1993), and before the U.S. Supreme Court; the U.S. Courts of Appeals for the Federal, Second, Fifth, and Ninth Circuits; the U.S. Tax Court; the U.S. Court of Federal Claims; and the U.S. District Courts for the Middle and Northern Districts of Georgia, the Western District of New York, the Eastern, Northern, and Western Districts of Texas, the Western District of Washington, and the Eastern District of Michigan.

• Recognition & Leadership

Todd was named a Law360 “Tax MVP” in 2014, and in that same year the tax controversy practice he chaired was recognized as the North American Tax Disputes Firm of the Year by Legal 500. In 2015, Law360 recognized his victory in Schaeffler v. United States as one of the Biggest Federal Tax Cases of the Year, and in 2016 Law360 again named him a Tax MVP. In 2018, he chaired McDermott Will & Emery’s Tax Controversy Practice when it was named the Tax Litigation Law Firm of the Year. In 2019, Todd left McDermott Will & Emery to focus his time and practice on select tax controversy engagements.

• Professional Involvement

Todd is an active author and thought leader on tax controversy matters, with recent publications including “Jarkesy, Originalism, and the Future of Tax Penalties” (April 2026). His work has been featured in firm news, including Kostelanetz’s successful challenge to the IRS’s AI-augmented conservation easement appraisal reports at trial (April 2026) and the firm’s 2026 Chambers USA rankings in tax controversy, tax fraud, tax law, and white-collar litigation.

• Experience

Todd has extensive experience resolving civil tax matters at all stages, from IRS examinations and appeals through litigation. Because of the nature of his work, many matters remain confidential, but his representative work includes a current select, multifaceted, high-profile engagement involving one of the IRS’s highest-priority enforcement campaigns, and numerous transfer pricing matters involving service or procurement companies. In 3F Administracao de Recursos LTDA (n.k.a. Gavea Investimentos LTDA) v. Commissioner, he represented a high-profile taxpayer in Tax Court against IRS efforts to convert a private equity and hedge fund manager’s $250 million-plus capital gains on the sale of a management company into ordinary income under sections 741 and 751; the case settled in early 2019 with additional tax of less than $150,000 due. He represented a multinational company against IRS attempts to reclassify billions of dollars of debt as equity, resulting in the IRS administratively conceding 100% of approximately $9 billion of tax adjustments and hundreds of millions of dollars in penalties, and represented another multinational in connection with the valuation of intangibles under the asset-by-asset requirements of Code section 367(d), resulting in hundreds of millions in tax savings. His notable litigation victories include Schaeffler v. United States, 806 F.3d 34 (2d Cir. 2015), a taxpayer victory Law360 named one of the “Biggest Federal Tax Cases of 2015” and described as the “most favorable” privilege and work product decision in years; Alterman v. Commissioner (T.C. 2015), described by Law360 as a “rare” taxpayer victory; the Southgate Master Fund cases (N.D. Tex.; aff’d 5th Cir. 2011), a series of related matters with over $300 million at issue that concluded with DOJ conceding issues and refunds in 2016 totaling more than $225 million; and Rawls Trading, L.P. v. Commissioner, 138 T.C. 271 (2012), a Son of BOSS case involving $400 million in losses that was the first major Tax Court case to sustain the taxpayer’s reasonable cause defense to penalties. He is also experienced in abating penalties and interest following tax disputes, including interest abatement under I.R.C. § 6404 and interest suspension and abatement requests pursuant to the COVID-19 disaster period under I.R.C. §§ 7508A and 7508A(d). Todd joined Kostelanetz LLP in 2024 after serving as President & CEO of Todd Welty, P.C., a specialized tax dispute boutique.

DAY 1, THURSDAY, JUNE 25, 2026

WELCOME – OPENING REMARKS | 8:00am – 8:05am

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

SESSION 1 – TAX COMPLIANCE AND ENFORCEMENT UPDATE: PART I | 8:05am – 8:30am

Amid an unprecedented federal workforce reduction, continuing IRS funding cuts, and dissolution of the DOJ Tax Division, today’s panels provide a comprehensive update on developments and priorities across the Treasury Department, DOJ Tax Division, and IRS relating to enforcement and compliance.

Caroline D. Ciraolo, Esq., Partner, Kostelanetz, Washington, DC
Pamela Grewal, Esq., Managing Director, Andersen Tax, San Francisco, CA

SESSION 2 – A VIEW FROM THE TOP – A CONVERSATION WITH IRS CEO FRANK BISIGNANO | 8:30am – 9:05am

IRS CEO Frank Bisignano shares his perspective on the agency’s strategic direction, operational priorities, and modernization efforts, addressing resource constraints, technology transformation, workforce initiatives, and the agency’s approach to enforcement and taxpayer service.

Moderator: Michael J. Desmond, Esq., Member and Tax Department Chair, Miller & Chevalier, Chartered, Washington, DC
Hon. Frank J. Bisignano, Chief Executive Officer, Internal Revenue Service, Washington, DC

SESSION 3 – UPDATES FROM THE IRS COMPLIANCE OPERATIONS | 9:05am – 10:00am

As the IRS seeks to maximize human capital, tools, technology, and process efficiencies for sound tax administration encompassing both service and compliance, a panel of IRS compliance executives provides insight into IRS operations, resources, and priorities.

Moderator: Sharon Katz-Pearlman, Esq., Shareholder, Greenberg Traurig, New York, NY
Lia Colbert, Commissioner, Small Business/Self-Employed Division, Internal Revenue Service, Washington, DC Mabeline Baldwin, CPA, Acting Commissioner, Large Business and International Division, Internal Revenue Service, Washington, DC
Edward R. Killen, Esq., Commissioner, Tax Exempt and Government Entities, Internal Revenue Service, Washington, DC
Erick Martinez, Acting Director, Whistleblower Office, Internal Revenue Service, Washington, DC

Break | 10:00am – 10:10am

SESSION 4 – UPDATE FROM THE US TAX COURT AND THE IRS OFFICE OF CHIEF COUNSEL | 10:10am – 10:55am

This panel provides insight into the Tax Court’s operations, pending cases, and challenges in the current resource-constrained environment, and discusses the IRS Office of Chief Counsel’s leadership, staffing, workload, priorities, and field counsel’s role advising Exam and Appeals.

Moderator: Jennifer Breen, Esq., Partner, Morgan Lewis & Bockius, Washington, DC
Moderator: Diana L. Erbsen, Esq., Partner, DLA Piper, New York, NY
The Hon. Patrick J. Urda, Chief Judge, United States Tax Court, Washington, DC
Kenneth J. Kies, Esq., Acting Chief Counsel, Internal Revenue Service; Assistant Secretary, Tax Policy, US Department of the Treasury, Washington, DC

Break | 10:55am – 11:05am

SESSION 5 – ERC – FROM AMENDED RETURNS TO THE COURTROOM | 11:05am – 12:00pm

This panel explores the current landscape of Employee Retention Credit claims, including recent trends in audits, administrative appeals, and pending litigation, managing the risk of parallel proceedings, and best practices and strategies for substantiating and defending claims.

Moderator: Christopher M. Ferguson, Esq., Partner, Kostelanetz, New York, NY
Megan E. Marlin, Esq., Principal, PwC, Washington, DC
Daniel Graham Strickland, Esq., Partner, Holland & Knight, Washington, DC
Leila D. Carney, Esq., Member, Caplin & Drysdale, Chartered, Washington, DC
Eric Hylton, National Director, alliant, Washington, DC

Lunch | 12:00pm – 1:00pm

BREAK OUT SESSIONS | 1:00pm – 1:50pm

TRACK III

SESSION 6 – SEEKING AN INDEPENDENT REVIEW – THE CURRENT STATE OF IRS APPEALS AND ADR

With workforce reductions and leadership departures altering the IRS Independent Office of Appeals, this panel dissects the office’s operational reality, including Post Appeals Mediation, how Appeals balances independence against modernization goals, and best practices for the administrative appeals and ADR process.

Moderator: Darren John Guillot, National Director, alliant, Washington, DC
Elizabeth P. Askey, Esq., Of Counsel, Skadden, Arps, Slate, Meagher & Flom, Washington, DC
Tomika L. Bullet, CPA, Principal, Tax Controversy, Windham Brannon, Atlanta, GA
Yvonne R. Cort, Esq., Partner, Capell Barnett Matalon & Schoenfeld, Syosset, NY

Break | 1:50pm – 2:10pm

BREAK OUT SESSIONS | 2:10pm – 3:00pm

TRACK III

SESSION 7 – MVPs – WORKING WITH ACCOUNTANTS IN TAX CONTROVERSIES, LITIGATION, AND INVESTIGATIONS

Bringing together tax controversy attorneys, forensic accountants, and a former IRS-CI special agent, this panel explores integrating financial experts at every stage of a dispute, leveraging forensic accounting to strengthen cases, manage risk, and communicate financial narratives clearly.

Moderator: Daniel Nettles, Esq., Director, Andersen Tax, Costa Mesa, CA
Daniel Mayo, Esq., Partner, WithumSmith+Brown, PC, Red Bank, NJ
G. Michelle Ferreira, Esq., Managing Shareholder, Greenberg Traurig, San Francisco, CA
Michelle F. Schwerin, Esq., CPA, Shareholder, Neill Schwerin Boxerman, PC, St. Louis, MO
Kathy A. Enstrom, MBA, EA, COO and Director of Investigations, Moore Tax Law Group, Chicago, IL

Break | 3:00pm – 3:20pm

BREAK OUT SESSIONS | 3:20pm – 4:10pm

TRACK III

SESSION 8 – COLLECTION ALTERNATIVES FOR YOUR HIGH WEALTH CLIENTS

With the national tax gap estimated at $696 billion and the IRS focused on high-wealth taxpayers with balances due, this panel reviews current IRS collection, enforcement priorities, revenue officers’ investigative tools, asset valuation challenges, and negotiation tactics.

Moderator: Beverly Winstead, Esq., Principal, Law Office of Beverly Winstead, Baltimore, MD
Barbara T. Kaplan, Esq., Shareholder, Greenberg Traurig, New York, NY
Jeffrey D. Trevillion, Jr., Esq., CPA, Director, Crowe & Dunlevy, Oklahoma City, OK
Jessica Marine, Esq., Partner, Frost Law, Annapolis, MD

Break | 4:10pm – 4:30pm

BREAK OUT SESSIONS | 4:30pm – 5:30pm

TRACK III

SESSION 9 – A PRACTICAL GUIDE AND BEST PRACTICES FOR TAX REFUND LITIGATION

When disputes go beyond administrative appeals, this panel provides a practical roadmap for federal tax refund litigation, including administrative prerequisites, forum selection between US District Courts and the Court of Federal Claims, evidentiary strategies, and recent developments.

Moderator: Jeffrey M. Sklarz, Esq., Founding Partner, Green & Sklarz, New Haven, CT
Lindsay L. Clayton, Esq., Assistant Chief, Western Civil Trial Section, Tax Division, US Department of Justice, Washington, DC
Andrew Strelka, Esq., Partner, Willkie Farr & Gallagher, Washington DC
Justin L. Campolieta, Esq., Partner, Jones Day, New York, NY
Sandra R. Brown, Esq., Principal, Hochman Salkin Toscher Perez, PC, Beverly Hills, CA

DAY2, FRIDAY, JUNE 26, 2025

SESSION 1 – TAX COMPLIANCE AND ENFORCEMENT UPDATE: PART II | 8:30am – 9:00am

WELCOME ABOARD! A CONVERSATION WITH THE DOJ CIVIL DIVISION TAX LITIGATION BRANCH

With civil tax litigation now under the new DOJ Civil Division Tax Litigation Branch, inaugural head Joshua Wu discusses the office’s creation, mission, role in refund litigation, early priorities, and what the structural shift means for practitioners.

Moderator: Caroline D. Ciraolo, Esq., Partner, Kostelanetz, Washington, DC
Joshua Wu, Esq., Deputy Assistant Attorney General for the Tax Litigation Branch, US Department of Justice, Civil Division, Washington, DC

Break | 9:00am – 9:10am

SESSION 2 – FOLLOWING THE MONEY: A CONVERSATION WITH JAROD KOOPMAN, CHIEF, IRS CRIMINAL INVESTIGATION | 9:10am – 9:40am

IRS-CI Chief Koopman discusses the agency’s staffing, resources, global footprint, and enforcement priorities, focusing on how CI identifies and develops cases involving complex financial transactions, digital assets, and cross-border activity, plus investigative trends and interagency coordination.

Moderator: Don Fort, CPA, Senior Investigator, Kostelanetz, Washington, DC
Moderator: Guy Ficco, CFE, Senior Investigator, Kostelanetz, Washington, DC
Jarod Koopman, Chief, Criminal Investigation Division; Chief Tax Compliance Officer, Internal Revenue Service, Washington, DC

Break | 9:40am – 9:50am

SESSION 3 – NEW DOJ NATIONAL FRAUD ENFORCEMENT DIVISION | 9 :50am – 10 :20am

As DOJ intensifies its crackdown on financial fraud, this panel offers a rare chance to hear from Department leadership about the new National Fraud Enforcement Division’s mission, leadership, staffing, resources, enforcement priorities, and achievements combatting criminal tax violations.

Moderator: Karen E. Kelly, Esq., Partner, Kostelanetz, Washington, DC
Stephen Weiss, Esq., Associate Deputy Attorney General, Office of the Deputy Attorney General, US Department of Justice, Washington, DC

Break | 10:20am – 10:35am

SESSION 4 – A LOOK INSIDE TREASURY: A CONVERSATION WITH SHELLEY LEONARD, DEPUTY TAX LEGISLATIVE COUNSEL | 10:35am – 11:05am

Deputy Tax Legislative Counsel Shelley Leonard provides a look inside Treasury’s role in offering legal and policy advice on tax legislation, regulations, and guidance, addressing current legislative and regulatory priorities, the rulemaking process, and real-world impacts of recent changes.

Moderator: Scott Levine, Esq., Partner, Baker McKenzie, Washington, DC
Shelley Leonard, Esq., Deputy Tax Legislative Counsel, Office of Tax Policy, US Department of the Treasury, Washington, DC

Break | 11:05am – 11:15am

SESSION 5 – LEADING THE CHARGE: A CONVERSATION WITH ERIN COLLINS, NATIONAL TAXPAYER ADVOCATE | 11:15am – 11:45am

National Taxpayer Advocate Erin Collins provides an inside look at the current state of tax administration, the impact of the 2026 filing season, NTA’s June Objective Report to Congress, the Taxpayer Assistance and Service Act, and protecting taxpayer rights.

Moderator: Pamela Grewal, Esq., Managing Director, Andersen Tax, San Francisco, CA
Erin M. Collins, Esq., National Taxpayer Advocate, Internal Revenue Service, Washington, DC

Lunch | 11:45am – 12:10pm

SESSION 6 – GUIDING THE EXEMPT ORGANIZATION IN AN ERA OF ENHANCED ENFORCEMENT | 12:10pm – 1:10pm

With exempt organizations facing unprecedented scrutiny under Executive Orders, this panel examines current audit trends, compliance challenges, and key risk areas including governance, unrelated business income, and operational compliance, plus strategies for examinations and raising constitutional challenges.

Moderator: Meghan R. Biss, Esq., Partner, Loeb & Loeb, Washington, DC
Susanne Sachsman Grooms, Esq., Partner, Cooley, Washington, DC
Casey A. Lothamer, Esq., Senior Counsel, Loeb & Loeb, Washington, DC
Michelle McCarthy, Esq., Senior Manager, RSM US, Hartford, CT

BREAK OUT SESSIONS | 1:30pm – 2:20pm

TRACK III

SESSION 7 – OUR FRIENDS TO THE NORTH: RULES OF THE ROAD FOR US CANADA CROSS BORDER TAX CONTROVERSIES

This panel explores cross-border controversy issues including coordinated enforcement, exchange of information, limitation periods, and dispute resolution under the Canada-US treaty, following an imagined
case study through procedural steps and managing cross-border audits, MAP/ACAP, and multi-jurisdictional litigation.

Moderator: Christopher Slade, Esq., Partner, Aird & Berlis, Toronto, Canada
Amanda P. Swartz, Esq., Of Counsel, Meadows, Collier, Reed, Cousins, Crouch & Ungerman, Dallas, TX
J. Clark Armitage, Esq., Member, Caplin & Drysdale, Chartered, Washington, DC
Amie Colwell Breslow, Esq., Of Counsel, Jones Day, Washington, DC

Break | 2:20pm – 2:35pm

BREAK OUT SESSIONS | 2:35pm – 3:35pm

TRACK III

SESSION 8 – PRIVILEGE, CONFIDENTIALITY, & WORK PRODUCT IN THE AGE OF AI *ETHICS

As AI tools reshape how tax professionals create and share information, this panel explores how attorney-client privilege and work product protection apply, discussing data-sharing risks, privilege preservation, the ethical landscape, and practical steps to safeguard sensitive information.

Moderator: Michael Sardar, Esq., Partner, Kostelanetz, New York, NY
Caitlin R. Tharp, Esq. Partner, Steptoe, Washington, DC
Kimberly B. Tyson, Esq., Managing Partner, K. Tyson Law, PLLC, Charlotte, NC
Conor P. Desmond, Esq., Associate, Caplin & Drysdale, Chartered, Washington, DC

Break | 3:35pm – 3:50pm

BREAK OUT SESSIONS | 3:50pm – 4:50pm

TRACK III

SESSION 9 – RIPPED FROM THE HEADLINES: HIGH IMPACT CIVIL TAX DECISIONS

Analyzing a recent wave of high-profile tax cases, this panel addresses economic substance post-Liberty Global, self-employment income under Sirius Solutions, and failure-to-pay defenses under Kwong and Jarkesy, covering key holdings and their implications for audit strategy and litigation risk.

Moderator: Jason B. Grover, Esq., Counsel, Latham & Watkins, Chicago, IL
Gilbert S. Rothenberg, Esq., Adjunct Professor, American University, Washington, DC
Sanford J. Boxerman, Esq., Shareholder, Neill Schwerin Boxerman, PC, St. Louis, MO
Rachel Borden, Esq., Counsel, Mayer Brown, Washington, DC
Todd Welty, Esq., Partner, Kostelanetz, Atlanta, GA