Tax Controversies: Addressing Potential Implications to the Year Ahead

Ian M. Comisky is a litigation partner at Fox Rothschild LLP with more than 35 years of experience representing corporations and individuals in civil and criminal tax litigation, white-collar criminal defense and complex commercial disputes. Ian concentrates his practice in representing individuals and entities with respect to U.S. tax and foreign asset reporting obligations under FBAR and FATCA as well as other information reporting requirements. He also counsels individuals and corporations in civil audits and criminal investigations . Ian is a co-author of the two-volume treatise Tax Fraud and Evasion. He was elected in 1995 to the American College of Tax Counsel and is an adjunct professor at the University of Pennsylvania Law School teaching a course that covers FBAR reporting and related issues. Fox Rothschild is a full-service law firm with 21 offices coast to coast. Key practice areas include Bankruptcy, Corporate, Gaming, Employment, Entertainment, Intellectual Property, Litigation, Privacy & Data Security, Real Estate and Tax.

Curtis Elliott is one of the leading tax litigators in the United States. He has over 30 years of experience litigating civil and criminal tax cases, including IRS audits and appeals, and grand jury proceedings. He has extensive courtroom trial experience in the U.S. Tax Court, the Federal District Courts and state courts. His tax advocacy has resolved some of the most complex, high stakes tax cases for clients. Mr. Elliott's clients include Fortune 500 companies, entrepreneurial companies, estates and individuals. He works closely with co-counsel and CPA firms. Mr. Elliott is a Fellow in the American College of Tax Counsel, and is very active in the ABA Section of Taxation. He speaks at conferences across the country on tax dispute topics. Mr. Elliott also co-authored the nationally published treatise entitled Valuation Practice in Estate Planning and Litigation (Clark Boardman Callahan, 1994).

David Gannaway is a Principal with PKF O’Connor Davies’ Forensic, Litigation and Valuation Services group. With more than 25 years’ experience, he has served as both an IRS Special Agent, handling criminal investigations, and a private sector consultant, unraveling complex domestic and international white-collar financial fraud schemes across numerous business sectors, including healthcare, non-profit and financial services, among others. Applying high-level technical expertise, he is recognized for preparing meticulous damage calculations and successfully refuting the computations presented by opposing witnesses. With a widely-respected record of producing impressive and favorable results in criminal and civil trials at both the state and federal levels, Mr. Gannaway is an exceptional client advocate in tax controversies, white-collar criminal investigations, offshore IRS disclosure issues, shareholder disputes and settlement negotiations.

Mr. Gannaway is a frequent speaker at industry conferences and a thought leader in the areas of preventing and detecting fraud, money laundering, civil and criminal income taxes, regulatory compliance, the Foreign Corrupt Practices (FCPA) and Bank Secrecy Acts.