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

This event occurred in the past

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

This event occurred in the past

Date and Time


    Joan B. Kroc Institute for Peace and Justice, Theatre

    5998 Alcala Park San Diego, CA 92110




    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 ego 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.

    We are excited to announce Steve Toscher as the recipient of the 2018 Richard Carpenter Excellence in Tax Award. Toscher is one of the most highly regarded tax attorneys in the country, and a principal of the law firm of Hochman, Salkin, Rettig, Toscher & Perez, P.C., in Beverly Hills, California where he specializes in civil and criminal tax litigation.

    In addition to being a leading tax attorney in the country, he is also an Adjunct Professor at the University of Southern California, School of Accounting, where he teaches Federal Tax Procedure. Toscher is a Certified Tax Specialist in Taxation, the State Bar of California Board of Legal Specialization, a Fellow of the American College of Tax Counsel and has received an "AV" rating from Martindale Hubble. He is a past Chair of the Taxation Section of the Los Angeles County Bar Association and served as the tax editor on the Editorial Board of the Los Angeles Lawyer.

    Prior to entering private practice, Toscher served as a Trial Attorney with the Tax Division of the United States Department of Justice, where he received its Outstanding Attorney Award. He is a summa cum laude graduate of the University of San Diego School of Law and a former Internal Revenue Agent. Toscher is a frequent lecturer and author on tax controversy topics, including FBAR and other international enforcement matters. In addition to his many periodical publications, he is a co-author of Tax Management's "Tax Crimes" Portfolio.

    Toscher is widely regarded as a leader in the field of tax controversy. We are honored to present him with the 2018 Richard Carpenter Excellence in Tax Award.


    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 June 20) After June 20
    General Registration  $345
    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




    Program Schedule

    Friday, July 20, 2018

    8:30 – 8:45 a.m.

    Opening Remarks 

    • Miranda Perry Fleischer, Herzog Endowed Professor of Law and Co-Director of Tax Programs, University of San Diego
    • Ronson Shamoun, Principal Attorney & CEO RJS Law, Adjunct Professor of Law, University of San Diego School of Law
    • Michelle Breed, Acting Local Taxpayer Advocate - San Diego
    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 Cadenas, 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, LLP (Moderator)
    • Steven Walker, Principal at Law Offices of Steven Walker, APLC
    • Richard Carpenter, Principal at Richard Carpenter Tax Law Office
    • David J. Warner, Attorney, Holtz, Slavett & Drabkin
    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.
    • Richard Ormond, Shareholder Buchalter Law Firm
    • Doug Youmans, Partner at Wagner, Kirkman, Blaine, Klomparens & Youmans LLP
    • Welcome Remarks, Margaret Dalton, Associate Dean and Professor of Law, University of San Diego School of Law
    • Keynote Speaker: 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, Professor of Law, UC Irvine School of Law
    • 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 Procedure Workshop: IRS Enforcement of Cryptocurrencies; Updates & Options for Disclosure of Offshore Accounts & Assets; and a Nuts & Bolts of Criminal Tax Representation

    The Criminal Tax Workshop will provide a broad overview of topics ranging from a practical guide for handling sensitive civil examinations, criminal investigations, and defending criminal prosecutions to the IRS’ enforcement of Cryptocurrencies as well as an update on the IRS Offshore Voluntary Disclosure Program (OVDP) that is set to expire in September 2018. 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; 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
    • Damon Rowe, Special Agent in Charge, IRS Criminal Investigation 
    • Phillip Halpern, Assistant US Attorney, Southern District of California
    5:30 – 9:00 p.m.

    Celebrate & 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!

    • Keynote Speaker: Selvi Stanislaus, Chief Executive Officer, Franchise Tax Board (FTB) 


    • 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 this event has been approved for 6.5 hours of general MCLE credit hours and 1.0 hour of Legal Ethics MCLE credit hours.

      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 Sponsors:

      abacus logo

      ADP logo




      Carpenter IRS Tax


      wells faro

      Bronze Sponsors:

      bank of the west logo

      bernal loaw



      kennedy insurance

      mcHard Accounting


      ob deli


      Marketing Partner:

      san diego county bar association


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

    • 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


      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.

      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.


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    5998 Alcalá Park
    San Diego, CA 92110