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

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

Pamela Grewal is a managing director in the US National Tax practice at Andersen, based in San Francisco, California. 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 as she litigated cases for various divisions and advised numerous examination teams on a wide range of issues.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.”