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

David W. Foster is a partner in the Tax Disputes Practice Group in the Washington, D.C. office of Kirkland & Ellis LLP. David advises a broad range of clients, including large corporations, private equity firms and hedge funds, partnerships, estates, exempt organizations, and individuals, many of whom are subject to the IRS’s Global High Wealth initiative. His practice covers a diverse range of tax issues, including BBA partnership audit and litigation procedures, energy tax credits, international tax and transfer pricing, challenges to tax-exempt status, taxation of financial products, estate and gift taxes, deferred compensation, voluntary disclosures, and criminal tax. A former Supreme Court clerk for Justice Kennedy, David has prepared briefs and argued before many of the federal courts of appeals. He lectures regularly to in-house tax departments and professional associations.

Nikki S. Bossert is a Senior Technician Reviewer at the IRS Office of Chief Counsel, Procedure & Administration, Branch 6, working in the Richmond, Virginia office. Ms. Bossert works primarily on matters involving the economic substance doctrine, the BBA partnership audit rules, and FOIA. The IRS Office of Chief Counsel serves as the chief legal advisor to the IRS Commissioner on the interpretation, administration, and enforcement of the Internal Revenue laws, providing legal guidance and interpretive advice to the IRS, Treasury, and taxpayers.

Julie Ciamporcero Avetta is a Senior Attorney Advisor focusing on litigation at the Tax Law Center at NYU Law. Previously, Julie litigated federal tax controversies at the trial and appellate levels, and served as counsel to several political appointees, in the Tax Division of the U.S. Department of Justice. Julie has authored more than seven dozen federal appellate and Supreme Court briefs, presented oral argument in 48 appeals, and won precedential victories in all 13 circuits of the U.S. Courts of Appeals.

S. Starling Marshall is a partner in the Litigation and Tax groups in Crowell & Moring’s New York office. A trial lawyer with over 15 years of experience, she has successfully represented clients before federal and state courts, arbitration panels, and administrative tribunals. When clients face complex commercial and tax disputes, they rely on Starling as their advocate and counselor, and she guides them toward business-minded solutions throughout all phases of an investigation or litigation. In addition to representing clients in all stages of litigation, she guides clients through complex IRS audits and administrative appeals, provides tax-related advice, conducts internal investigations, and represents individuals and corporate entities in criminal tax matters.

Ellen Seiler Brody, for more than 20 years, has represented U.S. and international clients in tax controversy matters. Her clients include individuals, trusts, estates, corporations, and partnerships, including audits conducted under the IRS’s centralized audit regime of the Bipartisan Budget Act of 2015. Ellen represents clients during IRS audits and at appeals, as well as in litigation before the U.S. Tax Court, the U.S. Court of Federal Claims, and Federal district courts. She successfully litigated Grecian Magnesite, which overruled a long-standing IRS Revenue Ruling. Additionally, she is experienced with New York State and City tax controversy and has represented clients in matters involving personal income tax; corporate franchise tax; general corporation tax; unincorporated business income tax; commercial rent tax; and real estate transfer tax and real property transfer tax, representing clients during the audit, at conciliation, and in litigation before administrative bodies.

Jonathan Kalinski specializes in both civil and criminal tax controversies, as well as sensitive tax matters including disclosures of previously undeclared interests in foreign financial accounts and assets, and provides tax advice to taxpayers and their advisors throughout the world. He handles both Federal and state tax matters involving individuals, corporations, partnerships, limited liability companies, and trusts and estates. Mr. Kalinski has considerable experience handling complex civil tax examinations, administrative appeals, and tax collection matters.

Matthew Cooper serves as Leader of the Federal Tax Controversy Group in Deloitte Tax LLP’s Washington National Tax Office, based in Washington, D.C. He is a recognized leader in tax law, with a distinguished career that bridges both public service and the private sector. Before joining Deloitte, Matt held a prominent position as special counsel at the IRS, where he provided strategic counsel to the IRS, the U.S. Department of Justice, tax practitioners, and the broader public, offering insight across a wide spectrum of administrative and judicial tax practice. His responsibilities included steering some of the agency’s most prominent initiatives, such as guiding the economic substance doctrine and launching the return preparer initiative, and he was a go-to resource for complex procedural tax matters—advising on penalties, refunds, the Tax Equity and Fiscal Responsibility Act, Circular 230, and power of attorney rules.

Cory Ellenson is a Managing Director in the US National Tax practice at Andersen, based in Washington, D.C., specializing in tax controversy. Cory has more than 13 years of experience navigating IRS audits and appeals and addressing IRS practice and procedure matters. He represents clients through all stages of IRS audits and appeals, including negotiating and responding to information document requests, negotiating proposed adjustments and settlements, and working with outside counsel to support and defend tax positions. Cory also resolves all IRS practice and procedure matters, including penalty abatement, 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.

Zhanna A. Ziering, a tax controversy and litigation attorney, is the Managing Member of Ziering & Esman PLLC, based in New York City. Ms. Ziering represents individual and entity taxpayers in civil and criminal tax matters before taxing authorities and enforcement agencies, including the Internal Revenue Service, the Department of Justice, and state tax authorities. She has represented clients in federal and state courts, including the United States Tax Court and the Court of Federal Claims. A zealous advocate for her clients, Ms. Ziering assists clients in all stages of the tax controversy and litigation cycle, approaching each client with compassion and understanding and working collaboratively to develop a strategy specifically tailored to the unique needs of each client. She also provides pro bono tax representation to artists across film, music, and fashion, and is committed to defending taxpayers facing penalties for international reporting noncompliance, frequently undertaking projects and cases on a pro bono basis. A native Russian speaker, Ms. Ziering lives in New Jersey.

Jason B. Freeman is the founding member of Freeman Law, PLLC. He is a dual-credentialed attorney-CPA, author, law professor, and trial attorney. Mr. Freeman represents clients in litigation and disputes, with a particular focus on federal and state tax controversies, as well as white-collar and financial disputes, both civil and criminal. He handles IRS audits and other investigations and represents clients facing tax and white-collar or financial-related charges, and also advises and assists clients with tax and regulatory compliance, including domestic and international tax planning and regulatory reporting requirements, as well as cryptocurrency and blockchain matters. Mr. Freeman serves as trial counsel in complex business and commercial disputes, trying cases to juries and to the bench, and frequently serves as an expert witness. He is also a Forbes contributor for tax and white-collar legal matters.

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.

Chad Vanderhoef is a tax attorney based in Holland & Knight’s Tampa and Washington, D.C., offices, where he focuses his practice on tax controversy and litigation, offshore tax and reporting compliance (such as Reports of Foreign Bank and Financial Accounts/FBARs and international information returns), cross-border tax planning, and foreign investment in U.S. real estate. His practice includes representing clients in tax controversy matters, including U.S. Tax Court and federal district and appellate court litigation, as well as IRS examination and appeals, and he advises clients in connection with IRS tax and reporting remediation options. Mr. Vanderhoef also advises clients in connection with cross-border restructuring matters, including foreign investment in U.S. real estate.

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.

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.

Joshua D. Smeltzer is an experienced trial lawyer, Board Certified tax law specialist, and trusted advisor to corporations, partnerships, family offices, and high-net-worth individuals, based in Gray Reed’s Dallas and Houston offices. A former trial attorney with the U.S. Department of Justice, Joshua brings more than two decades of government and private-sector experience to high-stakes civil and criminal federal court litigation across the country, with matters ranging from $500,000 to over $1.5 billion. Chair of the Tax Controversy & Litigation practice and co-chair of the firm’s Blockchain and Digital Asset practice, he focuses on distilling highly technical tax, financial, and regulatory issues into clear themes that resonate with judges, juries, and government agencies, and he represents clients through every stage of a controversy with the federal government, including complex litigation in federal district courts, the U.S. Tax Court, and other federal forums. His litigation and advisory work spans financial services, private equity, energy, real estate, and emerging technologies such as artificial intelligence and digital assets. A recognized thought leader on tax, corporate governance, digital assets, and regulatory compliance, Joshua serves as editor of Gray Reed’s Dollars & Sense blog and contributes regularly to Forbes and other national publications.

Kathleen King is a Managing Director and National R&D Practice Leader with Alvarez & Marsal Tax, LLC in Washington, D.C. With more than 25 years of experience, Ms. King specializes in assisting clients in claiming, documenting, and sustaining tax incentives, including research tax credits, the meals and entertainment deduction, energy credits, work opportunity tax credits, and state credits. She has worked with clients across various industries, including aerospace and defense, food products, manufacturing, pharmaceutical products, retail, and software. Her projects have ranged from targeted consulting engagements designed to address specific issues to large-scale projects utilizing engagement teams working concurrently in multiple locations.

Andy Weiner is Counsel with Kostelanetz LLP, based in the firm’s Washington, D.C. office. He focuses on tax controversies, both civil and criminal, in trial and appellate courts and at the agency level. A Fellow of the American College of Tax Counsel, Andy is a frequent writer and speaker on tax issues. He has handled a wide diversity of matters in areas such as partnership taxation, corporate taxation and reorganizations, taxation of S corporations, tax accounting methods, income tax, gift and estate taxes, and collections, combining a deep knowledge of tax law with extensive litigation and administrative practice experience.

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.

Abbey Garber is a tax attorney in Holland & Knight’s Dallas office. Mr. Garber focuses his practice on tax litigation and providing advice in connection with applying tax laws to individuals, estates, corporations, and partnerships. He has experience in all aspects of IRS practice, including audit, appeals, collection, and litigation, and works with a range of clients, including individuals, small businesses, and multinational corporations, to resolve their tax disputes.

Niles A. Elber, a Member in Caplin & Drysdale’s Washington, D.C., office, has more than 20 years of experience representing clients in civil and criminal tax controversies. His practice is broad, ranging on the civil side from IRS examinations, Appeals matters, collections, and proceedings in federal court, while on the criminal side handling both administrative and grand jury tax investigations. With considerable experience in offshore compliance matters for U.S. taxpayers, Mr. Elber has assisted hundreds of clients with their voluntary disclosures and income tax and FBAR penalty exams related to unreported foreign bank accounts. He is particularly focused these days on defending clients who find themselves caught up in aggressive IRS campaigns against alleged abusive tax shelters and transactions, and he most recently represented a defendant in one of the largest and most significant tax cases brought by the U.S. Department of Justice in the “conservation easement” area.

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.

Jed Dwyer is a trial lawyer who focuses his practice on criminal and civil tax litigation, white collar criminal defense matters, and complex civil litigation, at his boutique trial firm Dwyer Law, P.A. in Miami. Jed has tried more than 40 jury and non-jury trials and has been involved in over 100 investigations, many of which included complex fraud and regulatory matters. A proven strategic thinker with significant trial and investigative experience, Jed is routinely called on to represent individuals and companies in their most important matters, both criminal and civil, including proceedings concerning tax fraud, money laundering, corruption, health care fraud, False Claims Act matters, and civil fraud.

Tino Lisella is a Shareholder at Carlton Fields, based in West Palm Beach, and a former FINRA enforcement director and former federal tax prosecutor. Tino’s practice focuses on securities enforcement, civil and criminal tax controversy, and white collar litigation. He represents individuals and entities in complex securities matters and government investigations, as well as regulatory investigations and enforcement, and brings firsthand knowledge of the boots-on-the-ground strategies and priorities that prosecutors and FINRA enforcement attorneys use to build their cases—and the most effective strategies to defend against them. Tino also has significant experience in matters involving vulnerable adults and elderly customers.

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.

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.

Sara Neill is a Shareholder at Neill Schwerin Boxerman, P.C. in St. Louis, where she focuses her practice on representing clients with serious civil and criminal tax problems. Her success as an attorney is attributable to her dedication to her clients and desire to obtain the best possible results for them, a great deal of hard work, and her deep experience and knowledge of the federal tax system. Sara regularly represents individual and business clients in matters such as audits, administrative appeals, and litigation, and advises clients with sensitive tax problems, such as those who have failed to file returns, underreported income, neglected to remit trust fund or other employment taxes, or failed to pay significant amounts of tax due. She frequently represents clients in IRS criminal tax investigations and litigation, has defended numerous lawyers, accountants, and other tax professionals in IRS preparer/promoter penalty investigations and appeals as well as in criminal tax cases, and advises tax professionals on matters involving Circular 230 and on ethics and disciplinary matters before their professional licensing boards.

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.

Wendy Abkin is a tax attorney with Abkin Law PLC in Berkeley, California, representing clients facing both routine and highly complex tax disputes with the IRS, California tax agencies, county Assessors and Assessment Appeals Boards, and city tax agencies. Her clients include individuals, trusts and estates, business entities (partnerships, LLCs, and corporations), and non-profits. With more than 35 years of experience as a tax lawyer, Wendy specializes in tax audits, administrative appeals, and litigating tax disputes, and she has worked both in private practice—with small, mid-size, and large law firms—and in government service. She regularly advises clients on California residency disputes and has assisted numerous trusts in understanding and managing their exposure to California income tax.

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.

Fran Obeid is the founder of MFO LAW, P.C. in New York City. She represents individual and corporate clients in civil and criminal matters involving the Internal Revenue Service, state and city tax agencies, the United States Attorney’s Office, the District Attorney’s Office, the New York State Attorney General, and other government agencies. Ms. Obeid has represented numerous clients residing throughout the world with undisclosed offshore accounts, advising on disclosure and compliance alternatives and guiding them through the process, and she defends clients in federal and state audits, including residency and sales tax audits, while advising on how to prevent such audits. She regularly interacts with revenue officers and agents, IRS Appeals officers, IRS Counsel, criminal investigators, Assistant United States Attorneys, and Assistant Attorneys General, taking the right approach to best meet the client’s needs—whether defending a civil examination, criminal investigation or indictment, or subpoena demand.

Sarah Green is a senior managing associate at Dentons Sirote in Birmingham, Alabama, where she is a member of the Tax practice. With a strong focus on tax controversy and litigation, she represents clients during all phases of federal income tax disputes, including IRS audits, administrative appeals, and court proceedings in the U.S. Tax Court, federal district court, and the U.S. Courts of Appeals. With experience navigating a diverse array of complex tax issues, Sarah focuses on federal and state civil tax controversies, including representing clients in sensitive audits, administrative appeals, and litigation. She also provides tax advice and represents individuals and entities in criminal tax investigations and prosecutions.