- Moderator, Collections of Foreign Tax Judgments: When Your Other Problems Come Home, ABA Section of Taxation, 2020 ABA Midyear Meeting, January 31, 2020
- Panelist, From the Experts: Tax Controversy and Tax Litigation—Civil and Criminal Tax Update, NYU 78th Institute on Federal Taxation, November 10, 2019
- Moderator, From the Experts: Tax Controversy and Tax Litigation—Civil and Criminal Tax Update, NYU 78th Institute on Federal Taxation, October 20, 2019
- Panelist, How Well Do Your Secrets Travel? Understanding the Scope of Privileges in Cross-Border Audits and Investigations, NYU 11th Annual Tax Controversy Forum, NYU School of Professional Studies, June 20, 2019
- Panelist, From The Experts: Tax Controversy and Tax Litigation Update, NYU 77th Institute on Federal Taxation, November 11, 2018
- Moderator, From The Experts: Tax Controversy and Tax Litigation Update, NYU 77th Institute on Federal Taxation, October 21, 2018
- Speaker, The Impact of the U.S. Tax Reform on Brazilian Individuals, Companies and Investments, Brazil Tax Conference 2018, April 12, 2018
- Panelist, From The Experts: IRS Representation Tools, Techniques, and Defensive Strategies—Civil and Criminal Tax Update, NYU 76th Institute on Federal Taxation, October 22, 2017
- Presenter, Questions About Questions: How to Interview a Witness, ABA Section of Taxation, 2017 Joint Fall CLE Meeting, September 15, 2017
- Micro-Captive Transactions: What's Next and How Can You Prepare, AICPA, August 24, 2017
- Panelist, TOIs, Investigations, and Campaigns – the Tools of the IRS, Delaware Captive Insurance Association Spring Forum, May 8, 2017
- Speaker, Captive Insurance: New IRS Tax Reporting Regime, AICPA, December 19, 2016
- Speaker, Captive Insurance: New IRS Tax Reporting Regime Potential for Penalties and Examinations, Bloomberg BNA, December 9, 2016
- Panelist, Hot Audit/Controversy Issues, NYU 75th Institute on Federal Taxation, November 15, 2016
- Panelist, From The Experts: IRS Representation Tools, Techniques And Defensive Strategies – Civil & Criminal Tax Update, NYU 75th Institute on Federal Taxation, November 13, 2016
- Panelist, From The Experts: IRS Representation Tools, Techniques And Defensive Strategies – Civil & Criminal Tax Update, NYU 75th Institute on Federal Taxation, October 23, 2016
- Panelist, Hot Audit/Controversy Issues, NYU 75th Institute on Federal Taxation, October 23, 2016
- Representing Taxpayers Who Can't, or Won't, Pay: The Ins and Outs of Collection Due Process Cases, 8th Annual Tax Controversy Forum, NYU School of Professional Studies, June 24, 2016
- Panelist, Fines, Penalties and Costs to Settle Litigation, American Bar Association Section of Taxation, May 6, 2016
- Speaker, Litigating Partnership Tax Cases Under the New Partnership Tax Rules of the Bipartisan Budget Act of 2015, American Bar Association Section of Taxation, May 6, 2016
- Speaker, The New Partnership Audit Regime, 2016 Nashville TEI Spring Seminar, Tax Executives Institute, Inc., May 5, 2016
- Speaker, Nuts & Bolts of Tax Court Litigation: Post-Trial, ABA Tax Section, January 30, 2016
- Panelist, From the Experts: IRS Representation Tools, Techniques and Defensive Strategies - Civil & Criminal Tax Update, NYU 74th Institute on Federal Taxation, October 25, 2015
- Speaker, Examinations of TEFRA Partnership, American Law Institute Continuing Legal Education (ALI CLE), Handling a Tax Controversy 2015: Current Trends in Civil Tax Controversies and Litigation, October 8, 2015
- Speaker, IRS Audits and Appeals in the Issue Focused Exam Era, 2015 Nashville TEI Spring Seminar, May 20, 2015
- Panelist, Cross Border Privileges Issues, American Bar Association, 2015 May Meeting, May 8, 2015
- Chair, Court Procedure and Practice Roundtable Discussion, American Bar Association, 2015 May Meeting, May 8, 2015
- Panelist, Pre-Trial Planning & Judicial Precedence, American Bar Association, 2015 Midyear Meeting, January 30, 2015
- Panelist, From the Experts: Civil & Criminal Tax Controversy and Tax Litigation Update, New York University School of Professional Studies, 73rd Institute on Federal Taxation, November 16, 2014
- Speaker, Cascading Toward Extinction? The Continuing Assault on Privilege, Tax Executive Institute, Nashville Chapter, October 22, 2014
- Panelist, From the Experts: Civil and Criminal Tax Controversy and Tax Litigation Update, New York University, 73rd Institute on Federal Taxation, October 19, 2014
- Panelist, Tax Court Procedures: Pretrial Practices (Motions, Pretrial Memoranda, Stipulations of Fact, Exhibits and Witness Subpoenas), American Law Institute (ALI) CLE, Handling a Tax Controversy: Audit, Appeals, Litigation, & Collections, October 17, 2014
- Panelist, It's a Privilege, or Is It: Privilege Issues in Tax Cases, American Bar Associaton, 2014 Joint Fall CLE Meeting, September 19, 2014
- Chair, Court Procedure and Practice Roundtable Discussion, American Bar Association, 2014 Joint Fall CLE Meeting, September 19, 2014
- Speaker, The Scope of Attorney-Client Privilege After AD Investments, American Bar Association, June 18, 2014
- Speaker, Defending Taxpayer Penalties, Tax Executives Institute, May 22, 2014
- Moderator, U.S. Supreme Court and Appellate Tax Litigation: A Look at the Next Step, American Bar Association, 2014 May Meeting, May 9, 2014
- Moderator, Court Procedure & Practice Roundtable Discussion - The Trial Countdown, American Bar Association, 2014 May Meeting, May 9, 2014
- Chair, Court Procedure & Practice Committee, American Bar Association, 2014 May Meeting, May 9, 2014
- Panelist, The Presentation of Evidence - Stone Age to Space Age, U.S. Tax Court, May 1, 2014
- Speaker, Dodd-Frank Tax Issues, Columbia University, April 30, 2014
- Chair, Tax Shelter Promoter Litigation Issues, American Bar Association, October 18, 2013
- Chair, Settling TEFRA Cases, American Bar Association, October 18, 2013
- Speaker, Roundtable Discussion on International Best Practices on Tax Mediation, Supreme Court of the Philippines, Philippine Judicial Academy, October 18, 2013
- Speaker, Alternative Dispute Resolution in U.S. Tax Cases, Instituto Colombiano de Derecho Tributario's International Forum of Administration and Tax Justice, September 26, 2013
- Speaker, Seventh Circuit Adopts Majority View on Valuation Misstatement Penalty, American Bar Association, September 18, 2013
- Panelist, Using Alternative Dispute Resolution (ADR) to Resolve Tax Cases, American Bar Association, 2013 Midyear Meeting, January 25, 2013
- Panelist, Motions in Limine in Tax Court Forums, American Bar Association, 2012 May Meeting, May 11, 2012
- Speaker, Resolving Federal Tax Disputes: What Are My Alternatives, Tax Executives Institute, May 1, 2012
- Moderator, Parallel Civil Tax Litigation and Criminal Investigations, American Bar Association, 2012 Midyear Meeting, February 17, 2012
- Panelist, Current Trends in Tax Litigation: Economic Substance, Debt/Equity, and Entity Choice, District of Columbia Bar Association, January 19, 2012
- Moderator, The Scope and Nature of Section 6700 Litigation and Related Proceedings, American Bar Association, 2011 Midyear Meeting, January 21, 2011
- Moderator, Promoter and Material Advisor Litigation and Related Proceedings, American Bar Association, January 21, 2011
- Speaker, Stipulations in the Taxt Court, American Bar Association, January 11, 2010
- Chair, Atypical Statutes of Limitations Issues, American Bar Association, September 10, 2009
- Chair, Transferee Liability Issues: The Pursuit of Taxes, American Bar Association, January 10, 2009
- Chair, The Use of Jury Trials in Civil Tax Cases, American Bar Association, September 10, 2008
- Chair, Cross-Border Discovery in Civil Tax Controversies, American Bar Association, September 10, 2007
- Speaker, Unsettling Settlements: The Ambiguity of Section 162(f), Tax Executives Institutes, October 24, 2006
- Speaker, Recent Developments and Trends in Tax Shelter Litigation in the U.S. Court of Federal Claims and Federal District Courts, American Bar Association, February 10, 2006
- Speaker, Preclusion of Expert Witnesses, American Bar Association, September 10, 2004
Click here for a full list of speaking engagements.
- "Partnership Filing Relief,"
with Christopher S. Rizek, Charles M. Ruchelman, James E. Salles, and Jonathan R. Black, Caplin & Drysdale Client Alert, April 13, 2020
- "Deductibility of Illegal Payments, Fines, and Penalties" (Book),
with Rachel L. Partain, Bloomberg Tax 524-2nd Tax Management Portfolio, May 3, 2019
- "IRS's Offshore Voluntary Disclosure Program Ending: Impact on U.S. Taxpayers,"
with Zhanna A. Ziering, Benjamin Z. Eisenstat, Scott D. Michel, and Dianne C. Mehany, Caplin & Drysdale Client Alert, March 14, 2018
- "IRS to Revoke Passports for Seriously Delinquent Tax Debts Starting February 2018,"
with Dianne C. Mehany, Zhanna A. Ziering, Victor A. Jaramillo, and Christopher S. Rizek, Caplin & Drysdale Client Alert, February 12, 2018
- "Possible Tax Fallout for Student and Professional Athletes from NCAA-Related Investigations,"
with Victor A. Jaramillo and Scott D. Michel, Caplin & Drysdale Client Alert, November 9, 2017
- "Paradise Papers: U.S. Citizens and Residents Required to Report on Offshore Assets,"
with J. Clark Armitage, Peter A. Barnes, Kirsten Burmester, and Robert T. Carney, Caplin & Drysdale Client Alert, November 6, 2017
- "IRS Launches Issue-Based Corporate Compliance Campaigns,"
with J. Clark Armitage, Rachel L. Partain, and James E. Salles, International Law Office, February 24, 2017
- "IRS Launches Issue Based Corporate Compliance Campaigns,"
with J. Clark Armitage, Kirsten Burmester, Niles A. Elber, and Neal M. Kochman, Global Tax Weekly, February 16, 2017
- "IRS Launches 13 Issue-Based Corporate Compliance Campaigns,"
with J. Clark Armitage, Kirsten Burmester, Niles A. Elber, and Neal M. Kochman, Caplin & Drysdale Client Alert, February 3, 2017
- "Tax Plans Compared (December 2016) Corporate Tax,"
with Jonathan S. Brenner, Richard W. Skillman, Kirsten Burmester, and Peter A. Barnes, Global Tax Weekly, January 5, 2017
- "Tax Plans Compared (December 2016) Corporate Tax,"
with Jonathan S. Brenner, Richard W. Skillman, Kirsten Burmester, and Peter A. Barnes, Caplin & Drysdale Client Alert, December 16, 2016
- "Captive Insurance: New IRS Tax Reporting Regime Potential for Penalties and Examinations,"
with Rachel L. Partain, Christopher S. Rizek, and Charles M. Ruchelman, International Law Office, November 25, 2016
- "Captive Insurance: New IRS Tax Reporting Regime Potential for Penalties and Examinations,"
with Rachel L. Partain, Christopher S. Rizek, and Charles M. Ruchelman, Caplin & Drysdale Client Alert, November 3, 2016
- "Congress Enacts New Tax Examination and Collection Regime for Partnerships,"
with Charles M. Ruchelman, Christopher S. Rizek, and Rachel L. Partain, International Law Office, January 22, 2016
- "U.S. Passports in Jeopardy for Taxpayers Owing the IRS,"
with Dianne C. Mehany and Niles A. Elber, Global Tax Weekly, January 11, 2016
- "Congress Enacts Entirely New Tax Examination and Collection Regime for Partnerships,"
with Charles M. Ruchelman, Christopher S. Rizek, and Rachel L. Partain, Caplin & Drysdale Client Alert, December 10, 2015
- "The Final OECD BEPS Tome Has Arrived,"
with H. David Rosenbloom, Patricia Gimbel Lewis, J. Clark Armitage, and Peter A. Barnes, Caplin & Drysdale Client Alert, October 8, 2015
- "Transfer Pricing Audits: Flipping the Tested Party,"
with Peter A. Barnes, J. Clark Armitage, H. David Rosenbloom, and Neal M. Kochman, Wolters Kluwer, August 27, 2015
- "Transfer Pricing Audits: Flipping the Tested Party,"
with Peter A. Barnes, J. Clark Armitage, H. David Rosenbloom, and Neal M. Kochman, Caplin & Drysdale Client Alert, August 13, 2015
- "New Law Changes FBAR Filing Deadline,"
with Zhanna A. Ziering, Charles M. Ruchelman, Niles A. Elber, and Mark E. Matthews, Caplin & Drysdale Client Alert, August 10, 2015
- "IRS Releases Guidelines for Examining CFC Transactions,"
with Peter A. Barnes, J. Clark Armitage, H. David Rosenbloom, and Neal M. Kochman, Caplin & Drysdale Client Alert, July 29, 2015
- "Abusive Small Captive Insurance Companies on IRS 'Dirty Dozen' List,"
with Rachel L. Partain, Christopher S. Rizek, and Charles M. Ruchelman, International Law Office, February 27, 2015
- "Abusive Small Captive Insurance Companies Added to IRS "Dirty Dozen Tax Scams","
with Rachel L. Partain, Christopher S. Rizek, and Charles M. Ruchelman, Caplin & Drysdale Client Alert, February 13, 2015
- "Proposed New York Tax Changes Would Affect Large and Small Businesses,"
with Rachel L. Partain, International Law Office, January 30, 2015
- "NYC Proposed Tax Code Changes Would Affect Businesses Large and Small,"
with Rachel L. Partain, Caplin & Drysdale Client Alert, January 13, 2015
- "Switzerland Narrows Advance Notice to Account Holders of Treaty Requests: Americans with Unreported Accounts Impacted,"
with Scott D. Michel and Mark E. Matthews, Caplin & Drysdale Client Alert, December 16, 2014
- "IRS Issues Final Regulations On Material Advisor Penalties,"
Global Tax Weekly, September 4, 2014
- "IRS Issues Final Regulations on Material Adviser Penalties,"
with Christopher S. Rizek, International Law Office, August 29, 2014
- "IRS Issues Final Regulations on Material Advisor Penalties,"
with Christopher S. Rizek, Zhanna A. Ziering, and Rachel L. Partain, Caplin & Drysdale Client Alert, August 4, 2014
- "DOJ Deal with Swiss Banks Impacts U.S. Taxpayers and Financial Firms Around the World,"
with Cono R. Namorato, Scott D. Michel, and Mark E. Matthews, Caplin & Drysdale Client Alert, October 31, 2013
- "Professional Golfer Sergio Garcia to Owe More Taxes on Endorsement Income,"
with H. David Rosenbloom, Caplin & Drysdale Client Alert, March 15, 2013
- "LB&I Commissioner Provides Guidance to Examiners and Managers on the Codified Economic Substance Doctrine and Related Penalties,"
with Charles M. Ruchelman and Christopher S. Rizek, Caplin & Drysdale Client Alert, July 29, 2011
- "Taxpayer Wins LILO Case in the Court of Federal Claims,"
Real Estate Finance Journal, April 1, 2010
- "The New Battle In An Old War: Omissions From Gross Income,"
126 Tax Notes 1227, March 8, 2010
- "Treasury, IRS Continues Attack on Abusive Tax Transactions: Final Regulations for Reportable Transactions Issued,"
Derivatives Financial Products Report, September 1, 2007
- "The IRS Reorganization: Programs and Initiatives of the New Large Case Division,"
with Felix B. Laughlin, Administrative Law Review, Vol. 53, No. 2, May 1, 2001
- "The Hamas Deportation: Israel's Response to Terrorism During the Middle East Peace Process,"
10 Am. U. J. Intl'l & Pol'y 397, January 1, 1994
Click here for a full list of publications.
