17th Annual Tax Controversy Forum 2025 – Track II (Presented by NYU School of Professional Studies) (Day 2)

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.

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.

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.

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.

Dan Price’s practice focuses on tax and Title 31 (Bank Secrecy Act) controversy matters with the IRS and tax matters before certain state tax authorities. For over nineteen years, Dan served as an attorney in the IRS Office of Chief Counsel, and his experience as a former trial attorney, supervisory trial attorney, and Special Assistant United States Attorney gives him a distinctive perspective on tax controversy and tax administration. For federal tax and federal immigration matters, he accepts clients nationally.

Guinevere Moore represents taxpayers in significant disputes with the Internal Revenue Service, the Department of Justice, Tax Division, and state taxing agencies. She is the Managing Member of Moore Tax Law Group, LLC, a tax controversy and tax litigation firm with an office in Chicago. Guinevere has over fifteen years of experience helping taxpayers resolve significant disputes with the IRS and state tax agencies, and she routinely represents taxpayers in high-stakes criminal and civil tax disputes. She takes a holistic approach to representing clients, getting to know each client and developing a deep understanding of their needs and preferences before developing a strategy for the case. She is also a frequent speaker and author, routinely publishing articles and speaking at conferences around the world on tax controversy and tax litigation, including in Forbes, Bloomberg, and Tax Notes.

Rod Rosenstein is a member of the North America Litigation & Government Enforcement Practice Group and the Global Dispute Resolution Practice Group, based in Baker McKenzie’s Washington, DC office. He is co-chair of the firm’s National Security Practice, a team of former US government officials, former prosecutors, trade practitioners, and data privacy and cyber lawyers. During the administrations of Presidents George W. Bush, Barack Obama, and Donald Trump, Rod held senior political appointments as the Deputy Attorney General of the United States, US Attorney for the District of Maryland, and Principal Deputy Assistant Attorney General for tax enforcement in the US Department of Justice. He previously served as an Assistant US Attorney and a Criminal Division trial attorney, and represented the US government in 23 jury trials while arguing 21 civil and criminal cases in appellate courts and the US Supreme Court. He also served as a law clerk to Judge Douglas Ginsburg of the US Court of Appeals for the District of Columbia Circuit. As the second-highest ranking Department of Justice official, Rod managed a USD 28 billion budget and oversaw 115,000 employees in the Department’s litigating divisions, law enforcement agencies, and US Attorney’s Offices.

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.

Dean Zerbe is National Managing Director of alliantgroup and a partner at Zerbe, Miller, Fingeret, Frank & Jadav LLP, a law firm specializing in tax whistleblowers and tax litigation. He is also a Senior Policy Advisor to the National Whistleblower Center. Dean spent more than 25 years in congressional service, including as Senior Counsel and Tax Counsel for the Chairman of the U.S. Senate Finance Committee, Senator Charles E. Grassley, from 2001 to 2008. In that role, he was the driving force behind the legislation that created the modern IRS Whistleblower Office and expanded the rewards for tax whistleblowers. He has represented several tax whistleblowers — including Bradley Birkenfeld, who received the largest individual whistleblower award in U.S. history ($104 million) — and led the landmark Tax Court case Whistleblower 21276-13W v. IRS (2017), which established the definition of ‘collected proceeds’ under the whistleblower law. He holds a J.D. from George Mason University and an LL.M. in Taxation from New York University (notably also holding a BFA in Film Production from NYU). He was recognized by National Journal as one of the ‘Hill 100’ top congressional staffers.

Jennifer (Jenni) Black is a Managing Director in Citrin Cooperman’s National Tax Office, where she leads the Tax Procedure & Controversy practice. She brings more than two decades of combined legal and accounting experience to her role, with deep expertise in partnership audit procedures under both TEFRA and the Bipartisan Budget Act of 2015. Prior to joining Citrin Cooperman, Jenni served for 12 years as Senior Counsel in the IRS Office of Chief Counsel’s Procedure and Administration Division, where she was a principal author of the BBA regulations and played a central role in designing the forms and procedures for the BBA’s implementation. She earned a J.D., magna cum laude, from the University of Richmond School of Law and an LL.M. in Taxation with Distinction from Georgetown University Law Center, and holds a B.S. in Accounting and Finance from the University of South Carolina.

Carina Federico is a partner in Crowell & Moring’s Tax Group, resident in the firm’s Washington, D.C. office. She handles tax disputes at all stages, including IRS audits, IRS Appeals, federal district court litigation, tax court litigation, and appellate court litigation across the United States. Her experience includes serving as first chair at trial, taking and defending depositions, briefing a wide range of tax issues, negotiating settlements, and representing clients in IRS Appeals conferences. Carina counsels clients on tax policy matters by engaging regularly with key stakeholders at the Department of the Treasury and the Internal Revenue Service on behalf of clients seeking regulatory changes or clarity in existing regulations, and by submitting comments on proposed regulations and other guidance. She also advises taxpayers interested in claiming tax credits and incentives, including the energy tax credits under the Inflation Reduction Act.

Amish Shah is a tax attorney in Holland & Knight’s Washington, D.C., office. Mr. Shah focuses his practice on providing sophisticated and practical tax planning and tax controversy advice and representation to clients in the energy sector and to clients interested in achieving environmental, social and governance (ESG) goals through clean energy. He also advises clients in other sectors, including financial services, manufacturing, technology, and ecommerce. Mr. Shah has been advising clients with respect to energy tax credits for more than two decades across the full range of clean energy technologies, including production tax credits (PTCs) and investment tax credits (ITCs) for renewable power, alternative fuels, carbon capture, utilization and sequestration (CCUS), energy storage, hydrogen, biogas property, nuclear, and other technologies incentivized through tax credits, including under the Inflation Reduction Act. His representation spans the entire project life cycle, and he also represents clients in all phases of tax controversy at the administrative, trial court, and appellate levels, including many of the major energy tax controversy issues arising over the last two-plus decades.

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.

When high-stakes legal issues arise, Jeffrey A. Neiman is the first call for countless CEOs, entrepreneurs, celebrities, and influencers. A former federal prosecutor and seasoned litigator, Jeff regularly advises clients on defending against government investigations, resolving complex business disputes, and navigating high-profile tax controversies. At his core, Jeff is a trial lawyer— having successfully tried more than a dozen white-collar cases in federal court. He is a frequent speaker, panelist, and contributor at national conferences on topics such as offshore tax evasion, tax fraud, Ponzi schemes, and trial strategy.

Kelley C. Miller represents clients before the Internal Revenue Service in audits, examinations, and administrative appeals, and in litigation in the federal courts, most notably the U.S. Tax Court. She handles complex estate and gift tax litigation with the IRS, and for nearly two decades she has advised high net worth individuals and families on federal and state tax planning and estate and gift strategies. She practices from Loeb & Loeb’s Tysons office.

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.

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.