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The annual NYU School of Professional Studies Tax Controversy Forum features interactive presentations delivered by expert practitioners who cover a broad range of issues regarding tax audits and tax litigation at all levels.
Due to continued concerns regarding COVID-19, this year’s NYU Tax Controversy Forum will be produced remotely in a shortened format on Thursday and Friday, June 24 and 25, 2021.
This year’s NYU Tax Controversy Forum, in collaboration with CPAacademy.org, will feature updates on what the IRS is doing to enhance compliance through communication and enforcement. Panels will highlight the new IRS focus on intra-agency collaboration, new initiatives with respect to penalties and fraud referrals, and the IRS’s handling of tax collection challenges.
Tune in from your computer, at home, or the office, to hear from an exciting array of senior government representatives, including:
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Click here to view the full conference agenda.
12:00 – 1:30 PM
A DAY IN THE LIFE: A ROUNDTABLE DISCUSSION WITH SENIOR IRS EXECUTIVES ABOUT IRS OPERATIONAL AND ENFORCEMENT PRIORITIES
The Internal Revenue Service is a dynamic organization that constantly seeks new ways to further its mission of helping taxpayers comply with the tax law. The past year has been even more challenging than most, forcing a change in work routines and additional responsibilities to implement various stimulus initiatives. In addition, recent proposals to dramatically increase the IRS budget will revitalize the IRS and support its modernization efforts. In this program, senior IRS executives discuss emerging compliance trends and how the IRS charts policy, makes decisions and works synergistically to address non-compliance.
Charles P. Rettig, Esq., Commissioner, Internal Revenue Service, Washington, DC
Kevin Q. McIver, Chief of Staff, Internal Revenue Service, Washington, DC
Douglas W. O’Donnell, CPA, Deputy Commissioner, Services and Enforcement, Internal Revenue Service, Washington, DC
William M. Paul, Esq., Acting Chief Counsel, Internal Revenue Service, Washington, DC
Drita Tonuzi, Esq., Deputy Chief Counsel (Operations), Internal Revenue Service, Washington, DC
Jeffrey Tribiano, Deputy Commissioner for Operations Support, Internal Revenue Service, Washington, DC
1:30 – 2:30 PM
ENSURING TAX ACCOUNTABILITY OF LARGE ENTITIES AND WEALTHY TAXPAYERS – CURRENT PRIORITIES AND FUTURE PLANS OF THE LARGE BUSINESS AND INTERNATIONAL DIVISION OF THE IRS
LB&I is responsible for tax administration for domestic and international businesses with US tax reporting requirements and assets of $10 million or more and the Global High Wealth and International Compliance programs. This is your chance to meet the new leadership of LB&I and hear about the current state of the compliance campaigns, partnership audit activity, the IRS-wide high-income initiative, implementation of the Taxpayer First Act, the International Compliance Assurance Program, and other topics of interest to domestic and multinational entities.
Sharon Katz-Pearlman, Esq., National Principal-in-Charge, Tax Controversy Services, KPMG, New York, NY; Global Head, Tax Dispute Resolution and Controversy, KPMG International
Jennifer L. Best, Esq., Director, Treaty & Transfer Pricing Operations Practice Area, Internal Revenue Service, Washington, DC
Nikole C. Flax, Esq., Commissioner, Large Business & International Division, Internal Revenue Service, Washington, DC
Holly Paz, Esq., Deputy Commissioner, Large Business and International Division, Internal Revenue Service, Washington, DC
3:00 – 4:00 PM
FOCUS ON TAX PRACTITIONERS: ETHICAL AND PENALTY ISSUES
Tax practitioners are the gatekeepers to the country’s tax system and are subject to standards and penalties designed to ensure that practitioners give taxpayers clear and impartial advice about complying with the tax law. The Office of Professional Responsibility is charged with enforcing these standards and penalties. In addition, the IRS recently established the office of Promoter Investigations to focus on practitioners who promote abusive tax transactions. This panel discusses tax practitioner standards and how the IRS enforces those standards.
Sandra R. Brown, Esq., Principal, Hochman, Salkin, Toscher & Perez, PC, Beverly Hills, CA
Jonathan R. Black, Esq., Associate, Caplin & Drysdale, Chartered, Washington, DC
Lois Deitrich, CPA, Acting Director, Office of Promoter Investigations, Small Business/Self-Employed Division, InternalRevenue Service, Washington, DC
Sharyn M. Fisk, Esq., Director, Office of Professional Responsibility, Internal Revenue Service, Washington, DC
4:00 – 5:00 PM
EQUITY, DIVERSITY, AND INCLUSION IN TAX PRACTICE
The United States has more than 150 million taxpayers reporting more than $11 trillion of adjusted gross income each year. This huge group of taxpayers is extremely diverse, and the IRS is constantly working to serve each taxpayer better. Did you know that the IRS has policies to provide access for taxpayers with limited English proficiency and to make reasonable accommodations for taxpayers with disabilities? In addition, the IRS is subject to laws regarding non-discrimination, civil rights, and equal opportunity. This program addresses issues around bias and discrimination in tax practice, including how to report discrimination by IRS or IRS partners, IRS rules regarding Limited English Proficiencytaxpayers, and what to do about preparers who take advantage of immigrant and Limited English Proficiency communities.
Frank Agostino, Esq., President, Agostino & Associates, PC, Hackensack, NJ
Keisha Clark-Proctor, Associate Director, Civil Rights Unit, Equity, Diversity, and Inclusion Office, Internal Revenue Service, Washington, DC
Valerie A. Gunter, Chief Diversity Officer, Equity, Diversity, and Inclusion Office, Internal Revenue Service, Washington, DC
5:00 – 6:00 PM
TIPS FOR HANDLING AUDITS OF PASS-THROUGH ENTITIES UNDER THE CENTRALIZED PARTNERSHIP AUDIT REGIME
The use of partnerships and other flow-through structures has continued to expand and now accounts for over 50% of all net business income in the United States. With a growing consensus around increased funding for the IRS, a significant uptick in partnership examination activity is expected, focusing mainly on complex ownership arrangements, cross-border activities, and structured transactions. For most, these examinations will be conducted under the new centralized partnership audit regime. However, for partnerships that elect out of the centralized audit regime, the IRS will have to audit, assess, and collect from individual partners. This panel discusses practical topics such as how the IRS links partnership and partner cases in its systems, IRS’ challenges in obtaining statute extensions from all partners, the potential for inconsistent results, and strategies for representing partnerships that have opted out of the centralized audit regime.
Michael J. Desmond, Esq., Partner, Gibson, Dunn & Crutcher, Los Angeles, CA
Megan L. Brackney, Esq., Partner, Kostelanetz & Fink, New York, NY
Rochelle Hodes, Esq., Principal, Washington National Tax, Crowe, Washington, DC
Holly Paz, Esq., Deputy Commissioner, Large Business and InternationalDivision, Internal Revenue Service, Washington, DC
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