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

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.

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.

Carlos F. Ortiz is a Partner at BakerHostetler, based in the firm’s New York office. A seasoned trial attorney, recognized by Law360 as a “Legal Lion of the Week” and by AmLaw’s Litigation Daily as a “Litigator of the Week,” Carlos focuses his practice on high-risk tax controversies, anti-corruption (Foreign Corrupt Practices Act (FCPA) and Foreign Extortion Protection Act (FEPA)), offshore tax issues, anti-money laundering, e-commerce fraud, and healthcare fraud, as well as allegations of fraud against government agencies and financial institutions. He has extensive experience representing U.S.- and foreign-based corporations and individuals in the pharmaceutical, financial services, healthcare, aerospace, energy, and telecommunications industries in connection with matters before enforcement and regulatory agencies, including the U.S. Department of Justice (DOJ), the Internal Revenue Service (IRS), the Securities and Exchange Commission (SEC), and various state attorneys general. Over his career in private practice, he has secured the declination of criminal charges for corporate and individual clients, and on several occasions has prevented the referral of charges for the target of criminal tax investigations.

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.

Ian Comisky is a Partner at Fox Rothschild LLP, based in the firm’s Philadelphia office, with more than 35 years of experience representing corporations and individuals in civil and criminal tax litigation, white collar criminal defense, and complex corporate and commercial disputes. His experience includes tax controversy work such as IRS administrative and grand jury investigations, Tax Court, Claims Court, and District Court trials and appeals, jeopardy and termination assessments, and responsible officer penalty and collection matters; corporate compliance matters involving the Bank Secrecy Act, USA PATRIOT Act, and FATCA for financial institutions including banks, broker-dealers, and mutual funds; commercial litigation focused on accounting and legal malpractice as well as securities and class action matters; and corporate internal investigations, including claims under the Foreign Corrupt Practices Act. Ian frequently advises individuals on their U.S. tax and foreign asset reporting (FBAR and FATCA) obligations and has represented hundreds of individuals with undisclosed foreign bank accounts through the IRS voluntary disclosure programs, and he also counsels individuals and corporations in civil audits and criminal investigations arising out of tax-sheltered investments.

Larry Campagna is a Shareholder at Chamberlain Hrdlicka, based in the firm’s Houston office, with an established reputation as an authoritative litigator in matters of business litigation, white-collar criminal defense, and particularly in federal, state, and local tax controversies. For more than 45 years, he has resolved thousands of civil and criminal litigation matters, many of which involved sophisticated and complex legal issues that established precedent in courts at the federal, state, and local levels. Highlights of his career include representing the first taxpayer to be awarded attorneys’ fees by the Fifth Circuit Court of Appeals, serving as lead counsel in one of the largest project cases in the history of the United States Tax Court, and successfully defending one of the world’s largest accounting firms in a tax malpractice case. He also teaches a course in the law of Tax Crimes and Money Laundering as an Adjunct Professor at the University of Houston Law Center.

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.

Jorge Oben-Cuadros is a Partner in Procopio’s Washington, D.C. office, where he advises clients on planning, controversy and litigation, and policy matters involving tax and trade. He represents multinational corporations, defense contractors, investment funds, high-net-worth individuals, and family offices — particularly from Latin America, Puerto Rico, and Europe — on complex U.S. and international matters. His practice centers on inbound structuring into the United States, cross-border planning, tariff exposure and mitigation, tax and trade litigation, and strategic guidance on tax and trade policy developments affecting global operations.

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.

Stephen Josey is Counsel in the Tax practice at Vinson & Elkins LLP, based in the firm’s New York office. He is an experienced tax controversy attorney who represents taxpayers in civil and criminal matters involving the Internal Revenue Service, the New York State Department of Taxation and Finance, and the United States Department of Justice. Stephen has extensive experience representing taxpayers during audits and administrative investigations and has litigated a wide range of tax disputes, including Tax Court matters, tax refund suits in federal trial courts, summons enforcement matters, collection actions, injunction suits, and bankruptcy disputes involving tax claim priority and dischargeability. He also has experience litigating tariff-related disputes in the U.S. Court of International Trade and the U.S. Court of Appeals for the Federal Circuit. As he describes his approach, he regularly draws upon the skills and knowledge gained from government experience to help clients resolve their tax disputes efficiently and fairly.

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.

Amish Shah is a Partner in the Tax practice at Holland & Knight LLP’s Washington, D.C. office, where he advises clients on complex tax planning and controversy matters, with a particular focus on the energy sector and clean energy initiatives. His practice spans the full lifecycle of energy projects, including structuring, financing, and monetizing tax incentives. Mr. Shah counsels clients on a wide array of energy tax credits, including production tax credits (PTCs), investment tax credits (ITCs), carbon capture, hydrogen, energy storage, and other technologies incentivized under evolving federal policy. He also represents clients before the U.S. Department of the Treasury and the IRS in connection with regulatory guidance and legislative developments.