8:30am Opening Remarks by the Chair.
8:35am Reports of Subcommittees. This meeting will feature an expanded format for Subcommittee reports including special government guests. Attorney-Client and Constitutional Privileges, Bradley L. Williams, Ice Miller LLP, Indianapolis, IN; Important Developments - Civil, Charles P. Rettig, Hochman Salkin Rettig Toscher & Perez PC, Beverly Hills, CA; Important Developments - Criminal, Caroline D. Ciraolo, Rosenberg Martin Funk Greenberg LLP, Baltimore, MD; Sentencing Guidelines, Niles Elber, Caplin & Drysdale Chartered Washington, DC; Monetary Violations and Forfeitures, James N. Mastracchio, Morgan Lewis & Bockius LLP, Washington, DC; Legislative and Administrative Developments, John Colvin, Chicoine & Hallett PS, Seattle, WA; International Tax Enforcement, Bruce Zagaris, Berliner Corcoran & Rowe LLP, Washington, DC; IRS Investigations and Practices, Josh Ungerman, Meadows Owens Collier Reed Cousins & Blau LLP, Dallas, TX.
9:30am Globalization and International Tax and Money Movement Enforcement: Cross-Currents in Tax Controversies, Reporting, Money Laundering, Counter-Terrorism Enforcement and Ethics. A panel discussion of international enforcement hot topics using hypotheticals. Moderators: Bruce Zagaris, Berliner Corcoran & Rowe LLP, Washington, DC; Scott Harty, Smith Gambrell & Russell LLP, Atlanta, GA. Panelists: Ricardo Cadenas, Branch Chief (International), IRS, Washington, DC; Joseph Marks Myers, International Monetary Fund, Washington, DC; Karen L. Hawkins, Taggart & Hawkins PC, Oakland, CA.
10:30am Controversy and the Tax Exempt: An Introduction. Traditionally, an area of non-litigious dispute resolution with the IRS, tax exempts are increasingly under scrutiny and facing significant exposure for noncompliance. Could this be the new frontier for tax litigation? This panel, designed for the non-expert, will provide an introduction to tax exempt controversy procedures and potential sanctions in such cases, including penalties and revocation of exempt status. Moderator: Marc Owens, Caplin & Drysdale Chartered, Washington, DC. Panelists: James Joseph, Arnold & Porter LLP, Washington, DC; Douglas Varley, Caplin & Drysdale Chartered, Washington, DC.
11:00am An Enforcement Update from the IRS Criminal Investigation Division. A presentation on current tax enforcement priorities and policies. Moderator: Josh Ungerman, Meadows Owens Collier Reed Cousins & Blau LLP, Dallas, TX. Panelist: Nancy Jardini, Chief, Criminal Investigation, IRS, Washington, DC.
LUNCHEON
Date: 5/6/06
Start Time: 12:00PM
End Time: 12:30PM
JOINT SESSION
Date: 5/6/06
Start Time: 12:30PM
End Time: 1:30PM
Topic: Practitioner Ethics -- The New Horizon: Proposed Amendments to Circular 230. Contingent fee limitations, open disciplinary proceedings, conflict of interest disclosures, new practitioner standards, procedures, sanctions and more. A panel discussion of issues raised by the latest proposed changes to the ethics rules governing tax practitioners. Moderator: Frederic L. Ballard, Jr., Ballard Spahr, Washington, DC. Panelists: Deborah Butler, Associate Chief Counsel, IRS (Procedure & Administration), Washington, DC; Steven Whitlock, Acting Director, IRS Office of Professional Responsibility, Washington, DC.