Third Annual USD School of Law - RJS LAW Tax Controversy Institute

Third Annual USD School of Law - RJS LAW Tax Controversy Institute

Date and Time

  • Friday, July 20, 2018 from 7:30 a.m. to 5:30 p.m.

Location

Joan B. Kroc Institute for Peace and Justice, Theatre

5998 Alcala Park San Diego, CA 92110

Cost

0

Details

The institute is the premier tax controversy event in San Diego. The region's top tax attorneys, CPAs, and law/business school professors will discuss topics including tax reform, alter eho assessments, criminal tax matters, and international business and taxation. It will also provide phenomenal networking opportunities to meet other top practitioners, tax attorneys, CPAs, EAs, tax preparers, and students are all welcome to attend.

Click here to view photos from the Second Annual USD School of Law - RJS LAW Tax Controversy Institute.

At the conference, the institute will be presenting the Richard Carpenter Award to a distinguished individual who illustrates the notable achievements of Richard Carpenter honoring his 30 years of excellence in the tax field and his continued commitment to the tax community. The award is given to individuals who personified honesty, integrity, ethics, and compassion throughout his/her careers in the field of tax controversy and have demonstrated outstanding dedication and expertise while representing taxpayers before the federal and state governments. The recipient of the 2018 Richard Carpenter Excellence in Tax Awards will be announced at the conference.

If you would like to make a contribution to the USD School of Law - RJS LAW Tax Controversy Institute, please click here. Thank you for your support.

 

 

Registration Information


Registration categories are listed below.

Registration Category Early Bird (by May 20) After May 20
General Registration  $345
$395
Attorneys (1-5 years), USD Alumni $300 $350
CPAs, Enrolled Agents, or Tax Preparers $245 $295
Government Employees $100  $150
Students $30 $30
Professors FREE FREE
Reception Only $75 $75

Discounts are available for groups of 2 or more (must be from the same organization). Please contact usdlawevent@sandiego.edu.

 

REGISTER

 

Program Schedule


Friday, July 20, 2018

7:30 – 8:30 a.m. CONTINENTAL BREAKFAST ⁄ REGISTRATION
8:30 – 8:45 a.m.

Opening Remarks 

  • Victor Fleischer, Director of Tax Programs & Professor of Law, University of San Diego School of Law
  • Ronson Shamoun, Principal Attorney & CEO RJS Law, Adjunct Professor of Law, University of San Diego School of Law
  • Debra A. Falcone, Taxpayer Advocate Service, Local Taxpayer Advocate
8:45 – 9:45 a.m.

Key Tax Challenges for International Businesses & Investors in California

In an increasingly globalized economy, taxpayers—from multinational corporations to globe-trotting individuals—can have financial dealings and information relevant to tax enforcement in many different countries. International agreements, including treaties, tax information exchange agreements, automatic exchange agreements, and local laws, dramatically affect whether and how information can be obtained and shared with other countries’ tax authorities. There are foreign developments in these areas that will affect California taxpayers investing internationally. Changes in foreign rules, including foreign tax credits and tax treaty changes, will lead to more differences internationally and likely more tax controversy disputes. Additionally, there are California tax developments that will also affect California taxpayer’s international taxes and investments.

  • John Forry, Managing Director at CBIZ, former partner at Ernst & Young (Moderator)
  • Paul Burns, CBIZ MHM, LLC
  • David Gill, International Tax Partner, Ernst & Young
  • Ricardo Cardenas, IRS Branch Chief, Office of Associate Chief Counsel (International)

9:50 – 10:50 a.m.

 

 

 

 

 

 

Protecting Your Client Against the Issuance of a Summons and Summons Enforcement

One of the many investigatory tools the IRS has at their disposal is the  issuance of summonses. With this tool the IRS can compel a taxpayer, as well as third parties, to appear and both provide testimony and produce documents.  Panelists will explore the different types of summons that can be issued in both civil and criminal cases, the scope of the  summons power, and how the issuance of summonses can affect the statute of limitations on assessment.  Additionally, panelists will discuss how to handle summons appearances, including the assertion of privileges,  dealing with third party summonses,  and  the “nuts and bolts” of what happens if the IRS agent  wants to seek enforcement of a summons because of a perceived failure to comply with the summons.

  • Lavar Taylor, Managing Partner at Law Offices of A. Lavar Taylor (Moderator)
  • Steven Walker, Principal at Law Offices of Steven Walker
  • Richard Carpenter, Principal at Richard Carpenter Tax Law Office
  • David J. Warner, Senior Attorney at IRS Office of Chief Counsel
10:50 – 11 a.m. BREAK
11 – 12 p.m.

Cannabis - Don't Let Your Practice Go Up in Smoke

Laws regarding cannabis use and legalization are changing rapidly, leading to confusion for tax professionals on how to service cannabis business clients safely. Raise your awareness of the practice risks in today’s volatile legal environment.

  • Kaelyn Romey, Associate Professor of Law, Golden Gate University (Moderator)
  • Jonathan Kalinski, Hochman, Salkin, Rettig, Toscher & Perez, P.C.
  • Doug Youmans, Partner at Wagner, Kirkman, Blaine, Klomparens & Youmans LLP
12 – 1:35 p.m. KEYNOTE SPEAKER LUNCHEON
  • Introduction by Stephen C. Ferruolo, Dean and Professor of Law, University of San Diego School of Law
  • Keynote Speaker: Chief Judge L. Paige Marvel, United States Tax Court 
1:35 – 1:45 p.m. BREAK
1:45 – 2:45 p.m.

Tax Reform - Big Changes, Big Planning Opportunities: What You Need to Know to Properly Advise Clients in 2018 and Beyond

Tax Reform is one of the hottest topics in the country right now. This panel will dive into some of the most significant proposals and explain how they may impact your clients and your practice. We'll explore the closing of loopholes, reduced corporate and pass through tax rates, and the limitations to itemized deductions. We'll also look at the U.S.'s move towards a territorial tax system and the phase out of the estate tax    

  • Howard Abrams, Professor of Law, Harvard Law School (Moderator)
  • Victor Fleischer, Director of Tax Programs & Professor of Law, University of San Diego School of Law
  • Frank Agostino, President, Agostino & Associates
  • Dr. Sarah Lyon, Professor, University of San Diego School of Business
2:45 – 2:55 p.m.  BREAK
2:55 – 3:55 p.m.

Alter Ego, Successor In Interest and Nominee Liabilities: What They Are and The Best Tips on How to Limit Your Client's Exposure

This panel will discuss third-party federal tax liens and what to do when the IRS tries to collect taxes that you do not owe. The panel will focus on the differences between nominee, transferee, successor, and alter-ego liability, the procedural safe-guards for third-party liability, discuss ways to protect against such liability, and how to deal with third-party IRS collections efforts. 

  • Ronson J. Shamoun, Principal Attorney & CEO, RJS LAW, Adjunct Professor, University of San Diego School of Law (Moderator)
  • Michael Dallo, Principal Attorney, Dallo Law Group
  • Erin Salel, Associate Area Counsel, IRS Chief Counsel, SBSE
  • Laura Buckley, Partner, Higgs, Fletcher & Mack
4:00 – 5:30 p.m.

Criminal Tax Workshop: The Nuts & Bolts of Criminal Tax Representation

The Criminal Tax Workshop is a practical guide for handling sensitive civil examinations, criminal investigations, and defending criminal prosecutions. The distinguished panelists will address when to anticipate a criminal referral; how to handle IRS Special Agent interviews of taxpayers or tax preparers; how to effectively represent a target, subject or witness in a criminal investigation; how to approach a conference with the Department of Justice; procedural
and trial issues that every criminal tax defense attorney should know; when and how to argue tax loss issues; effective plea negotiations; and strategies at employ at sentencing. Overall, this workshop will provide a “toolkit” of practice tips employed by experienced practitioners and government officials.

  • Steven Toscher, Principal, Hochman, Salkin, Rettig, Toscher & Perez, P.C. (Moderator)
  • Michael Lipman, Partner, Duane Morris' Trial Practice Group
  • Martin Schainbaum, Founder, Martin A. Schainbaum PLC: Tax Warriors
  • Nathan Hochman, Partner, Morgan, Lewis & Bockius, LLP
  • John D. (Don) Fort, Chief, IRS Criminal Investigation 
  • Philip Halpern,Assistant US Attorney, Southern District of California
5:30 – 9 p.m.

Celebreate & Connect! A Networking Opportunity Sponsored by Torrey Pines Bank

Come celebrate the day's achievements and join us for cocktails and hors d'oeuvres while you connect with sponsors and other tax professionals!

 

MCLE and Specialized Credits

Need Continuing Education Credits?


The University of San Diego School of Law is a State Bar of California-approved MCLE provider and can confirm that this event will be approved. The number of credit hours and to which area they will be applied will be determined closer to the event date. Please check back for updated details.

RJS LAW is a registered Continuing Education provider with the IRS and this event has been approved for 6.0 hours of IRS CE Credits.

Sponsors

 

USD School of Law logo   

 

Platinum Sponsor:

Torrey Pines

 

Silver Sponsor:

ADP logo

 

lavar-tci

 

Carpenter IRS Tax

 

wells faro

Bronze Sponsors:

bernal loaw

 

 coastal

 

mcHard Accounting

 

If you are interested in being a sponsor for the University of San Diego School of Law - RJS LAW Tax Controversy Institute, please email djrider@sandiego.edu

Location and Parking Directions

Joan B. Kroc Institute for Peace & Justice
Peace & Justice Theatre
University of San Diego
5998 Alcala Park, San Diego CA 92110

From the North From the South From the East
> Use I-5 South
> Exit Sea World Dr. &
Tecolote Rd.
> Proceed left at stoplight
toward Morena Blvd.
> Turn right on Morena Blvd.
> Left on Napa
> Left on Linda Vista Rd.
> Turn left on Marian Way for
West Entrance to campus
> Use I-5 North
> Exit Morena Blvd.
(signs will say: Morena
Blvd. use I-8 East)
> Stay to the right and follow
signs for Morena Blvd.
> Take the first right onto
Linda Vista Rd.
> Turn left on Marian Way for
West Entrance to campus
> Use I-8 West
> Exit at Morena Blvd.
> Go right onto
Linda Vista Rd.
> Turn left on Marian Way for
West Entrance to campus

PARKING INFORMATION:

Visitors are required to pay for parking on campus. Metered parking is available in multiple locations on campus but we recommend you park in the West Lot and take the tram to KIPJ. Rates for parking are as follows:

  • 30 minutes - $0.75
  • 1 Hour - $1.50
  • 2 Hour - $3
  • 4 Hour - $4
  • Full Day - $8

The pay stations on campus accept coins as well as Visa & Mastercard credit/debit cards. They do not accept cash or American Express cards.

PAY BY PLATE:
All paid parking areas at USD operate as pay-by-plate. This means that a license plate number is required when making a payment at the pay station. It may be helpful to take a picture of your license plate after you park your vehicle. Once you have made your payment, there is no need to display your receipt on your dashboard.

Phone

Contact Us

Phone: (619) 260-4527
lawdean@sandiego.edu

View Directory

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Visit Campus

Warren Hall, Room 201
5998 Alcalá Park
San Diego, CA 92110