18th Annual Tax Controversy Forum 2026 – Track I (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.

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.

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.

Elizabeth J. Stevens is a Member of Caplin & Drysdale, based in Washington, D.C., who practices across the firm’s International Tax, Tax Controversies, and Business, Investment & Transactional Tax groups. Her client representations span international tax and transfer pricing planning and advocacy for multinational corporations; U.S. investment and business structuring and transactional advice for foreign corporate groups; and domestic and cross-border tax structuring, transactional, and compliance advice to high-net-worth individuals and their privately held businesses. In the transfer pricing space, she advises corporate clients on planning, documentation, and compliance, with a particular focus on dispute resolution and prevention and tax certainty processes such as the Mutual Agreement Procedure (MAP) and Advance Pricing Agreements (APAs), and she regularly advises on other treaty-related matters such as the creation and taxation of permanent establishments, relief from double taxation for U.S. citizens resident outside the United States, corporate and individual tax residency determinations, and eligibility for treaty benefits.

Joseph A. DiRuzzo, III is an attorney and Certified Public Accountant with DiRuzzo & Company, based in Fort Lauderdale, Florida. His practice spans tax controversy, health care, digital assets, tax planning, white collar criminal defense, Virgin Islands taxation, appellate practice, and complex civil and governmental litigation. He brings a combined legal and accounting background to his work, having argued numerous appeals before multiple United States Courts of Appeals and tried cases before the U.S. Tax Court, and he is a Florida Bar Board Certified Specialist.

Phillip Colasanto is a Senior Associate in the private client and tax team at Withers, based in New York. His practice is focused on domestic and international tax controversy and compliance matters. He has represented clients before the U.S. Tax Court, U.S. district court, U.S. Court of Appeals, and various state courts, handling matters from audit through trial and at the appellate level. His experience includes examinations, collection matters, Appeals hearings (including collection due process hearings), innocent spouse relief, whistleblower claims, advising clients on international and domestic filing requirements and compliance options, and oral argument before the Tax Court and Court of Appeals.

Daniel “Dan” N. Price is the managing member of the Law Offices of Daniel N. Price, PLLC, based in San Antonio, Texas. His legal practice focuses on tax and Title 31 (Bank Secrecy Act) controversy matters with the IRS and tax matters before certain state tax authorities, including civil defense of IRS audits and criminal defense of IRS criminal investigations. For over nineteen years, he served as an attorney for the Office of Chief Counsel of the Internal Revenue Service, and as a former trial attorney and manager (supervisory trial attorney) with the Office of Chief Counsel and as a Special Assistant United States Attorney, he brings unique experience with tax controversy and tax administration. He has deep expertise concerning the IRS’s Voluntary Disclosure Practice, the Streamlined Filing Compliance Procedures, and international penalty regimes, and he assists taxpayers in coming into compliance and in battling significant IRS and state tax penalties.

Miri Forster is a Partner at Eisner Advisory Group LLC and National Leader of the firm’s Tax Controversy & Dispute Resolution practice group, based in Iselin, New Jersey. She specializes in providing tax dispute resolution services to public and private corporations, partnerships, and high-net-worth individuals on a wide range of technical and procedural issues, with over 20 years of IRS practice, procedure, and tax controversy experience. She represents businesses and individuals before the IRS Examination and Appeals Divisions on complex domestic and international tax issues, obtains private letter rulings from the IRS National Office (including 9100 relief requests for missed elections), assists clients with voluntary disclosures of inadvertent income, international information return, withholding, and payroll tax compliance errors, obtains penalty abatements and refunds, resolves IRS account issues, and advises on a broad range of IRS practice, procedure, and dispute resolution matters.

Elizabeth Julia Smith is Counsel in the Tax and Tax Controversy and Litigation practices at Skadden, Arps, Slate, Meagher & Flom LLP, based in Boston. She represents clients in administrative tax disputes and litigation, advising multinational corporations, private investment firms, and individuals in connection with IRS and state audits and administrative proceedings, trial and appellate litigation in federal and state courts, and proceedings brought by non-U.S. taxing authorities. She has represented clients across a variety of industries, including health care, energy, telecommunications, private investments, transportation, and technology and her experience encompasses a wide range of complex tax issues involving income, sales, self-employment, withholding, and property taxes.

Kevin Spencer is a Partner at White & Case LLP, based in Washington, DC, and head of the firm’s Tax Controversy practice. He advises on complex tax matters on behalf of businesses, tax-exempt entities, and high-net-worth individuals, with substantial experience assisting clients in resolving disputes with the Internal Revenue Service (IRS) at the IRS Appeals and Examination/Audit divisions and at competent authority, and litigating tax disputes in federal court (the U.S. Tax Court, U.S. District Court, U.S. Court of Federal Claims, and U.S. Circuit Courts of Appeals). In addition to his tax controversy practice, he advises clients on various tax issues, including tax accounting, civil and criminal tax penalties, IRS procedures, reportable transactions, and tax shelters.

Katherine Jordan is Counsel at Miller & Chevalier, where her practice centers on tax controversy and litigation. She guides clients through complex tax disputes with strategic insight and practical solutions, drawing on her strong legal writing and advocacy skills and her collaborative approach across legal, policy, and finance teams.

Mary E. Wood is a Partner at Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P., whose practice concentrates on resolving federal and state tax controversies, as well as white collar crime matters such as securities, tax, and bank fraud. She represents individuals, closely held businesses, and large corporations in IRS audits, appeals, and litigation in the United States Tax Court, Federal District Courts, and the United States Court of Federal Claims. Mary also represents taxpayers in disputes with the Texas Comptroller of Public Accounts and other state tax agencies, and she represents individuals and entities in business disputes and lawsuits involving fraud, breach of contract, breach of fiduciary duty, deceptive trade practices act violations, non-compete violations, business torts, and other commercial disputes. Prior to joining the firm in 2006, she was a litigation associate with a Texas law firm.

John W. Porter is a Partner at Baker Botts L.L.P., based in Houston, and one of the nation’s leading tax controversy attorneys, maintaining a nationwide practice representing high-net-worth individuals and businesses in sophisticated federal tax controversy matters. He has served as lead counsel for taxpayers in some of the most significant published estate and gift tax decisions of the last twenty-five years, including cases addressing formula clauses used to transfer hard-to-value assets, the application of I.R.C. § 2036 to family entities, the built-in capital gains discount when valuing stock, the “net-net gift discount,” the valuation of closely held entity interests, and the reasonable reliance defense to IRS penalties. He represents taxpayers in every aspect of the tax controversy practice — before the IRS (including examination, mediation, and appeals) and in litigation in the United States Tax Court, the United States Court of Federal Claims, the United States District Courts, and the United States Courts of Appeals — and also counsels clients on business and estate planning transactions, privilege issues, and fiduciary duty and trust and estate administration matters.

Kathryn A. Meyer is the Founder and Principal Attorney of Kathryn Meyer Law PC, based in Alexandria, Virginia. She is a tax attorney with extensive experience in federal tax litigation, IRS enforcement matters, and complex tax controversy work, bringing more than 26 years of service with the Internal Revenue Service Office of Chief Counsel to her private practice. Her work today focuses on helping individuals, professionals, and businesses nationwide navigate challenging tax disputes, audits, collections, and litigation, combining deep technical knowledge with practical strategy drawn from her experience inside the government.

Kelley Miller is a Partner at Loeb & Loeb LLP with nearly two decades of experience helping high net worth individuals and families navigate complex federal and state tax planning, estate and gift strategies, and federal tax controversy matters. Her clients include Fortune 500 public companies, privately held businesses, owners of closely held enterprises, family offices, and individuals with inherited wealth. She maintains extensive experience representing clients in audits and examinations before the Internal Revenue Service, including administrative appeals and litigation in federal courts—most notably the U.S. Tax Court—and her practice spans all stages of civil tax controversy at both the federal and state levels, representing corporations, partnerships, and individuals. Kelley also advises on matters at the intersection of civil and criminal tax law, has assisted clients with high-stakes matters involving the disclosure of offshore accounts and unreported income from digital assets such as cryptocurrency, and handles complex estate and gift tax litigation involving the IRS while counseling tax-exempt organizations—including private foundations and public charities—on compliance and controversy matters.

Michel R. Stein is a principal at Hochman Salkin Toscher Perez P.C., specializing in tax controversies as well as tax planning for individuals, businesses, and corporations. For more than 25 years, he has represented individuals with sensitive-issue civil tax examinations where substantial penalty issues may arise, and has extensively advised individuals on foreign and domestic voluntary disclosures regarding foreign account and asset compliance matters. He is well respected for his expertise and judgment in handling matters arising from the U.S. Government’s ongoing enforcement efforts regarding undeclared interests in foreign financial accounts and assets, including various methods of participating in a timely voluntary disclosure to minimize potential exposure to civil tax penalties and avoid a criminal tax prosecution referral. He has assisted hundreds of individuals who have come into compliance with their foreign reporting requirements through the OVDP, Streamlined Filing Compliance Procedures, or otherwise. Throughout his career, Mr. Stein has represented thousands of individual, business, and corporate taxpayers involved in civil examinations and administrative appeals, tax collection matters, and matters involving possible assertions of fraudulent conduct, and has defended criminal tax investigations and prosecutions at every administrative level within the IRS. He continues to provide tax advice to taxpayers and their advisors around the world.

Michelle Abroms Levin is a shareholder in Dentons Sirote’s Huntsville, Alabama office, where she is a member of the Tax practice group and manages the Huntsville office. She represents clients during all phases of federal income tax controversies, including IRS audit, administrative appeals, and court proceedings in the U.S. Tax Court, U.S. Court of Federal Claims, federal district court, and the Courts of Appeals. Michelle has secured major victories for her clients in the Eleventh Circuit, Fifth Circuit, and Tax Court, elevating important Administrative Procedure Act issues in the tax controversy context, and her experience includes a wide range of complex tax issues. She also counsels clients in tax and business planning, working with them to structure transactions in a manner that maximizes tax benefits, reduces risk, and complies with tax law at local, state, and federal levels. Prior to joining Dentons Sirote (formerly Sirote & Permutt, PC), Michelle worked as a trial attorney at the Tax Division of the U.S. Department of Justice, where she represented the United States in federal district court.

Melissa Wiley is a Partner at Kostelanetz LLP with more than 20 years of experience in tax law, having represented a diverse range of clients—from large corporations to high-net-worth individuals—in complex disputes with federal and state taxing authorities. Known for her calm, empathetic style, she excels at distilling intricate tax issues into clear, actionable insights, helping clients efficiently resolve disputes and focus on what matters most in their businesses and lives. Melissa serves as a trusted advisor to clients at all levels of administrative tax controversy, including audits, cases before the IRS Office of Appeals, and investigations by the IRS Office of Professional Responsibility, and she has significant experience handling penalty and international information reporting matters. When an administrative resolution cannot be reached, she is well-equipped to litigate, and she also represents clients facing government and third-party subpoenas and investigations while frequently advising on voluntary disclosures of prior tax noncompliance. An actuary by training, Melissa pairs a scrupulous, detail-oriented approach with a thorough understanding of how tax affects her clients’ financial affairs, and her background in statistics and the insurance industry has fostered a natural ability to collaborate effectively with technical and forensic experts.

Aaron M. Esman is an accomplished tax controversy and litigation attorney based in New York who represents individual and entity taxpayers before the Internal Revenue Service, the Department of Justice, and state and local taxing authorities. He represents taxpayers in all stages of tax controversy, including audits, appeals, and litigation, and he also advises clients on tax matters related to corporate transactions, mergers and acquisitions, compliance, and corporate governance. An active member of the American Bar Association Section of Taxation—where he serves as Chair of the Standards of Tax Practice Committee and Vice-Chair of the LGBTQ+ Lawyers in Tax Forum—Aaron is regularly asked to speak on tax matters for both tax and non-tax audiences and has moderated a series of panels alongside staff from the Internal Revenue Service. A proud supporter of the arts who can often be found at one of New York City’s great theaters, he also serves on the Alumni Board of Directors for the University of Miami.

Josh O. Ungerman is a partner at Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P., whose experience as a former IRS Senior Trial Attorney and Department of Justice Special Assistant U.S. Attorney is invaluable in helping clients with IRS civil tax and criminal tax controversy matters at all levels, along with tax and estate planning. The tax and estate matters in which Josh is involved are typically very complex from both a factual and legal perspective and often require both legal and accounting skills—Josh is also a Certified Public Accountant. He is engaged in defending taxpayers and issues against IRS inquiries and actions, with an IRS defense practice that covers civil and criminal exams, investigations, and trials, and many of his tax controversy matters include an offshore component. He is frequently called upon to remediate non-compliant offshore structures and advise on offshore compliance requirements, and he works with families on wealth preservation and transfer strategies. Josh is a frequent speaker on tax topics including domestic and offshore IRS exams, IRS estate tax strategies, tax shelter defense, recent tax legislation, IRS criminal tax investigation techniques, and state tax controversy issues.

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.

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.

Mike Waalkes is an associate with Kostelanetz LLP, based in the firm’s Washington, D.C. office. He focuses his practice on civil and criminal tax controversy matters, including audits, promoter investigations, voluntary disclosures, U.S. Tax Court litigation, and criminal tax investigations. Prior to joining the firm, Mike served for two years as a judicial law clerk for Judge Joseph W. Nega of the U.S. Tax Court. In addition to his practice, Mike is an adjunct professor at Villanova University’s Charles Widger School of Law, where he co-teaches a course on federal tax practice and procedure in the school’s graduate tax program. He also maintains an active pro bono practice representing low-income taxpayers before the Internal Revenue Service and the U.S. Tax Court.

Philipp Behrendt is licensed in California as well as in Germany and assists in advising clients in civil and criminal tax controversies as well as international money laundering investigations stemming from tax avoidance structures. He also focuses on the technical aspects involved in advising voluntary disclosures in connection with DeFis, NFTs, and other crypto assets. Prior to joining the firm, Mr. Behrendt worked for more than five years for a leading German tax firm, where he focused on representing wealthy individuals and companies in global tax settings, cross-border investigations and audit matters, as well as tax compliance issues arising from internationally functioning matrix structures.

Sean P. McElroy is a Partner in the Tax practice at Fenwick & West LLP, based in the firm’s Seattle office. He advises clients, including early-stage startups, unicorns, and Fortune 100 multinationals, on a wide array of domestic and international tax planning and tax controversy matters. Sean has particular expertise advising clients on tax matters related to blockchain and cryptocurrency ecosystems, having advised numerous clients on tax issues relating to token generation events, private token sales, NFTs, decentralized autonomous organizations (DAOs), and centralized and decentralized cryptocurrency structures. His clients in this space include protocol development teams, founders, investment platforms, cryptocurrency exchanges, and individual investors. Sean is a lecturer in law at Stanford Law School, where he taught courses in Corporate Income Tax and Blockchain Tax.

Amber Salotto is a Managing Director with RSM US LLP’s Washington National Tax compensation and benefits practice, where she specializes in executive compensation, equity compensation, qualified and nonqualified plans, and other related topics. Previously, she spent more than two years at the Department of the Treasury as an attorney-advisor to Benefits Tax Counsel within the Office of Tax Policy, where she was responsible for regulatory and legislative matters related to the taxation of compensation and benefits, including cryptocurrency, tax law changes under the TCJA, the SECURE Act, and various economic stimulus and COVID-19 relief measures. Earlier, she spent more than 10 years at Deloitte, most recently with their compensation and benefits practice in Washington National Tax, where she served as a national practice resource on cryptocurrency as compensation. She also previously served with the US National Tax Practice at Andersen.

Debra Silverman Herman is a partner in the State & Local Tax Practice at Hodgson Russ LLP, resident in the firm’s New York City and Hackensack, New Jersey offices. She is widely recognized for her experience in state and local taxation. Debra works with a variety of clients to address the state and local tax impact of their multistate activities from both a planning and an audit and controversy viewpoint and on complex transactions, with a focus on New York State tax matters. She counsels clients with respect to corporate income and franchise taxes, bank taxes, utility taxes, unincorporated business taxes, sales and use taxes, gross receipts taxes, excise taxes on real property transfers, rent and occupancy taxes, and withholding taxes. Debra also has extensive experience working with high-net-worth clients on residence and other personal income tax matters and successfully representing clients in all phases of tax disputes, including audits and litigation at the federal, state, and local levels, as well as criminal tax investigations.

Catherine Chiou is a Managing Director in Andersen’s State and Local Tax (SALT) practice in New York, NY. She has over 13 years of experience providing tax services to corporate and high-net-worth clients with regard to state and local tax compliance and consulting involving income and franchise taxes, sales and use taxes, gross receipts taxes, and unclaimed property. Catherine has advised a multitude of clients on state and local tax matters associated with tax refund and planning opportunities, tax controversies, voluntary disclosures, state residency planning, nexus reviews, and credits and incentives projects. She specializes in state and local tax consulting, advisory, audit defense and controversy, planning, and compliance.

Richard L. Jones is the leader of Sullivan & Worcester’s Tax Group, based in the firm’s Boston office. He concentrates on state and local tax (SALT) litigation and transactional planning involving corporate, personal income, and sales/use tax matters. He has more than two decades of experience before the Massachusetts Appellate Tax Board, the Supreme Judicial Court, various state Departments of Revenue, and the Internal Revenue Service on a range of issues, including corporate nexus, domicile, apportionment, step transaction, and unitary reporting. Rich has served clients across sectors including technology, financial services, retail, media, manufacturing, telecommunications, e-commerce, software, and construction.

Deanne Morton is a Managing Director in the Andersen US National Tax practice, based in San Francisco, CA, where she works within the firm’s Tax Controversy practice. A former practicing attorney with a master’s degree in taxation, Deanne draws on her over 20 years of experience to serve Andersen clients in navigating Federal Tax Controversy matters. She represents clients through all stages of IRS audits and appeals, including navigating and responding to information document requests, negotiating proposed adjustments and settlements, and working with outside counsel to support and defend tax positions. Deanne also resolves all IRS practice and procedure matters, including penalty abatement, disaster tax relief, voluntary disclosure, excise tax, employment tax, foreign and domestic information withholding and reporting, employee identification numbers, entity classification, R&D credit, transfer pricing, residency certifications, collection due process, and refund claims. In addition, she helps analyze tax policy and legislative developments, assists with business and individual tax planning, and plays an integral role in the firm’s thought leadership and knowledge management efforts.

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.

Gray Proctor is Counsel with Kostelanetz LLP, based in the firm’s Atlanta, GA office. He is a board-certified appellate specialist and one of fewer than one percent of active Florida Bar members to hold that designation. Gray focuses his practice on federal appellate litigation, with particular depth in tax controversy appeals and APA-based challenges to federal agency action. He brings a combination that is genuinely difficult to find: the procedural command of a dedicated appellate advocate with three federal clerkships, and the substantive fluency of a practitioner embedded in high-stakes tax litigation every day. His appellate practice spans the full arc of federal tax controversies — from preserving constitutional and statutory challenges in the U.S. Tax Court, to coordinating appellate strategy as cases move to the circuit courts, to briefing and oral advocacy in the circuits and the Supreme Court. He also serves as appellate co-counsel to trial firms handling matters outside tax, particularly cases turning on federal agency action and APA procedure. Beyond tax, Gray maintains an active criminal appellate practice; he accepts CJA appointments in the Sixth and Eleventh Circuits, has represented clients in death row clemency proceedings, and earlier in his career contributed to the successful reversal of a high-profile Tennessee murder conviction. He also accepts clients on appeal of civil matters outside of tax, including commercial litigation and insurance coverage.

John Colvin is an attorney with Colvin + Hallett, a tax law firm in Seattle, Washington. He draws from almost three decades of practice and experience in tax law to develop legal theories and strategies in defense of his clients, and he keeps a close eye on developments in the tax law, enabling him to provide clients with awareness of current developments and their implications. John is a very active and respected member of the American Bar Association Tax Section, having served as Chair of the Committee covering tax controversy matters, and he is often sought out to speak at a national level on various tax law issues. He also teaches Tax Crimes: Investigations, Prosecutions, and Penalties at the University of Washington School of Law. Outside of his practice, John is a wine and food connoisseur always on the lookout for Seattle’s next great restaurant, enjoys swimming, and is an avid reader of non-tax materials.

Kathleen Claussen is Professor of Law and the Anne Fleming Research Professor at Georgetown University Law Center, and a leader in international economic law and procedure who has served as arbitrator, counsel, expert, public servant, and teacher. Her expertise covers several topics of international law, especially trade, investment, international business, and labor; dispute settlement and international dispute bodies; national security and cybersecurity law; and administrative law issues surrounding U.S. foreign relations and transnational agreements. Professor Claussen has testified before the U.S. Congress and the European Parliament on topics related to trade agreements, U.S. tariff laws, and executive power, on which she is a leading authority. Since 2024, she has been Managing Faculty Co-Director of Georgetown’s Institute of International Economic Law, overseeing the Institute’s programming, budget, and administration, and she is co-founder of SAILS: the Consortium for the Study and Analysis of International Law Scholarship.

Nita Asher is a licensed attorney and a Principal in the Washington National Tax Office of PwC, within the firm’s International Tax Services practice, where she advises both U.S. and foreign-based companies on a wide range of international tax issues including financings, treaty qualification, and cross-border restructurings, with a particular focus on inbound multinationals. She advises companies on the impacts of tax policy, such as the implementation of the Tax Cuts and Jobs Act of 2017 (TCJA), and issues related to technical corrections, administrative guidance, and legislative changes to various provisions. Prior to rejoining PwC, she served as Legislation Counsel for the Joint Committee on Taxation (JCT), a nonpartisan committee of the United States Congress, where she was heavily involved in the development of the TCJA.