Kostelanetz & Fink Celebrates Another Successful NYU Tax Controversy Forum

On June 20 and June 21, 2019, Kostelanetz & Fink partner Bryan C. Skarlatos and Chamberlain, Hrdlicka, White, Williams and Aughtry shareholder David D. Aughtry co-chaired the 11th Annual New York University Tax Controversy Forum at the Crowne Plaza Hotel in Times Square.

This year’s Forum hosted the country’s leading tax professionals from both the government and private practice, including IRS Commissioner Charles P. Rettig; National Taxpayer Advocate Nina E. Olson; Michael R. Schmidt, Commissioner of the New York State Department of Taxation and Finance; Don Fort, Chief of the IRS Criminal Investigation; and Richard E. Zuckerman, Deputy Assistant Attorney General in the Department of Justice Tax Division.

In his keynote address, Commissioner Rettig discussed several reforms the IRS plans to implement, including close scrutiny of cryptocurrency transactions, focus on conservation easement donations and micro-captive insurance structures, and continued emphasis on criminal tax investigations. Commissioner Rettig also encouraged tax professionals in the audience to consider working for the agency saying, “It can be an experience that you find tremendously rewarding, and I think it’s an experience that you should reach out for.” Finally, Mr. Rettig attributed the success of the agency’s historic filing season, with more than 15 million returns processed, to its highly dedicated public servants.

National Taxpayer Advocate Nina Olson delivered a keynote address Friday morning and was awarded the NYU Tax Controversy Forum Lifetime Achievement Award. During her speech, Ms. Olson, called for a “Taxpayer Anxiety Index” to help the average taxpayer navigate the agency. She also proposed an “Economic Hardship Indicator” to use “as a factor in prioritizing and categorizing collection cases” to assist economically vulnerable taxpayers. Ms. Olson discussed her role in supporting the recent Taxpayer Bill of Rights and in helping establish Low-Income Taxpayer Clinics.

Other senior IRS officials including Chief Counsel Michael J. Desmond, Deputy Commissioners Douglas W. O’Donnell and Mary Beth Murphy and Director of Collections Paul J. Mamo also addressed tax compliance and enforcement at various conference panels. IRS International Special Counsel Lindsey D. Stellwagen, IRS Special Agent- in-Charge Jonathan D. Larsen, and DOJ Tax Division Litigation Counsel Mark F. Daly also addressed cross-border investigations.

Additional panel discussions included topics such as Partnership Representatives under the BBA, Current Initiatives at LB&I, the new IRS Voluntary Disclosure Program, Recent Developments Affecting Foreign Asset Reporting Penalties, International Privilege Issues, Challenging Tax Regulations Under the APA and Obtaining Section 9100 Relief.

An additional feature of this year’s Forum was the Problem Solving Days, where representatives of the IRS Local Taxpayer Advocates for Brooklyn and Manhattan, the New York State Department of Taxation and Finance and New York City Department of Finance were available to help tax professionals with unresolved tax problems. The various Taxpayer Advocates addressed and solved dozens of cases on site at the Forum.

Kostelanetz & Fink, as program sponsor and creator of the Forum, thanks all of the speakers from the government and private practice, as well as the numerous sponsors who made this year’s forum possible.