Tax Controversies: Addressing Potential Implications to the Year Ahead
With intensified tax controversies amid recent reforms and enforcement actions in the U.S. nowadays, taxpayers and professionals are left conjecturing about the potential implications these might bring to 2019. Significantly, these implications may either provide opportunities or pose more challenges for practitioners, chiefly due to the uncertain and ever-changing landscape of U.S. tax laws.
Thus, it becomes more imperative for practitioners to keep themselves abreast of the upcoming trends, developments and compliance updates to properly navigate and address resulting consequences. Doing so will help their clients avoid tax penalties and disputes.
Listen as a panel of distinguished professionals — organized by The Knowledge Group — provide the audience with an overview of the most significant tax controversies in 2018. Speakers, among other things, will provide helpful insights and their tax implications in 2019. They will also offer tips on how to properly navigate and address these matters, thus putting themselves in a better position.
In a LIVE Webcast, the speakers will discuss:
- Overview of the Most Significant 2018 U.S. Tax Reforms
- Relevant Tax Audits and Disputes
- Important Tax Controversies
- Potential Implications in 2019
- Navigating and Addressing Implications
Ian M. Comisky, Partner
Fox Rothschild LLP
- Post Marinello issues;
- Charging tax fraud as wire fraud and charging tax fraud as money laundering with asset forfeiture claims;
- Post Klein update on penalty abatement.
W. Curtis Elliott, Jr., Partner
Culp, Elliott & Carpenter, PLLC
- Access to IRS Administrative Appeals in Tax Court Cases
- New Acknowledgement of Facts Procedure, Large Cases
- Penalties and Prior Supervisory Approval under Section 6751(b)
David Gannaway, Principal
PKF O'Connor Davies LLP
- IRS CID Enforcement Priorities
- IRS Special Enforcement Program Revenue Agent
- Title 31 / BSA Audits
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.
Ian M. Comisky is a litigation partner at Fox Rothschild LLP with more than 35 years of experience representing corporations …
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).
Curtis Elliott is one of the leading tax litigators in the United States. He has over 30 years of experience …
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.
David Gannaway is a Principal with PKF O’Connor Davies’ Forensic, Litigation and Valuation Services group. With more than 25 years’ …
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Method Of Presentation:
Basic knowledge of tax laws
NY Category of CLE Credit:
Areas of Professional Practice
NASBA Field of Study:
Taxes – Technical
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About Fox Rothschild LLP
Fox Rothschild LLP is a national law firm known for excellent client service and agility in problem solving. Our lawyers provide a full range of services to public and private companies, from startups to multinational corporations, and prominent individuals, including celebrities, athletes, artists and entrepreneurs. Founded more than a century ago, Fox has grown significantly in recent years and is now ranked in the AmLaw 100, with 750 attorneys in 22 offices coast to coast.
About Culp, Elliott & Carpenter, PLLC
Culp Elliott & Carpenter, PLLC is a Charlotte, North Carolina tax law firm founded in 1982. It provides innovative tax, and legal solutions that create value for its clients, and helps clients achieve the most important goals in their businesses and lives. The Firm represents high-net-worth individuals, successful entrepreneurs, and corporate business clients. Firm members develop effective strategies to save on taxes, representing clients in the areas of estate planning, real estate and commercial transactions, mergers, acquisitions, restructuring and recapitalizations. Firm members handle civil and criminal tax litigation, and trusts and estates litigation, at all levels of dispute, and represent clients in disputes with the Internal Revenue Service. The Firm serves clients throughout the Southeastern United States.
About PKF O'Connor Davies LLP
PKF O’Connor Davies, LLP is a full-service certified public accounting and advisory firm with a long history of serving clients both domestically and internationally. With roots tracing to 1891, nine offices in New York, New Jersey, Connecticut and Maryland, and more than 700 professionals, the Firm provides a complete range of accounting, auditing, tax and management advisory services. PKF O’Connor Davies is ranked 29th on Accounting Today’s 2018 “Top 100 Firms” list and is recognized as one of the “Top 10 Fastest-Growing Firms.” PKF O’Connor Davies is also recognized as a “Leader in Audit and Accounting” and is ranked among the “Top Firms in the Mid-Atlantic,” by Accounting Today. In 2018, PKF O'Connor Davies was named by Vault as one of the 50 best accounting employers to work for in North America.