Times posted in Eastern Time (ET) and are subject to change.

Thursday, March 5

9:00 AM – 9:30 AM | Keynote Remarks and Q+A*

Join Charles P. “Chuck” Rettig, Former Commissioner, Internal Revenue Service (2018–2022) and Shareholder, Chamberlain Hrdlicka, as he delivers keynote remarks to kick off this year’s conference. A brief Q&A will follow.

*Session not available for CLE/CPE credit.

10:00 AM – 11:15 AM | IRS Operations and Tax Enforcement Priorities: The Path Ahead

The IRS is once again facing enormous challenges -significant reductions in budget and the workforce, the evaporation of $80 billion in supplemental funding as well as uncertainties within changing IRS leadership. This panel will discuss the current IRS operating environment, audit and enforcement priorities together with trends and recent developments in tax litigation within IRS Chief Counsel and DOJ.

• Moderator: Larry Campagna, Chairman Emeritus, Chamberlain, Hrdlicka, White, Williams & Aughtry
• Chuck Rettig, Shareholder, Chamberlain, Hrdlicka, White, Williams & Aughtry
• Carolyn Schenck, Member, Caplin & Drysdale

Learning Objectives:

• Identify current IRS operational, funding, and staffing challenges and their impact on enforcement and taxpayer services.
• Describe key IRS enforcement priorities, including high-wealth taxpayers, pass-through entities, and digital assets.
• Explain the role of data analytics and AI in IRS compliance, audit selection, and modernization efforts.
• Apply practical strategies for audit management and early resolution of tax disputes in the current IRS environment.

11:45 AM – 1:00 PM | OB3 Plus: Implications of OB3 and Additional Legislation & Guidance

This panel will update on the implications of OB3 (domestic and international) and Treasury guidance: where we were, what we’ve seen so far, and where we’re headed.

• Moderator: Scott Vance, Of Counsel, Tax, Skadden, Arps, Slate, Meagher & Flom LLP
• Julie Bolton, Associate Chief Counsel, Income Tax & Accounting, Office of Chief Counsel, IRS, U.S. Department of the Treasury (invited)
• Laura E. Al-Shathir, Shareholder, Capes Sokol
• Philip Lindenmuth, Executive Counsel to the Chief Counsel, Office of Chief Counsel, IRS, U.S. Department of the Treasury (invited)
• Marissa Rensen, Managing Director, KPMG US
• James Wang, International Tax Counsel, U.S. Department of the Treasury (invited)

Learning Objectives:

• Understand and summarize guidance concerning key domestic provisions in the OBBBA.
• Understand and summarize guidance concerning key international provisions in the OBBBA.
• Understand potential key legislative and regulatory guidance that may arise in the next few months.

1:30 PM – 2:45 PM | Tariffs in a Changing World: Navigating the Impact on Global Trade, Supply Chains, and Tax Compliance

This panel will examine the evolving role of tariffs in international trade. It will explore recent policy shifts, their effects on global supply chains, and the resulting tax compliance challenges for multinational businesses. Panelists will discuss strategies for managing tariff risks, adapting to new trade barriers, and anticipating future developments in the intersection of trade policy and taxation.

• Moderator: James Mulvehill, Managing Director, Trade & Customs Leader, KPMG US
• Matthew Bock, Managing Partner, Bock Trade Law
• Brian Gleicher, Member, Miller & Chevalier Chartered

Learning Objectives:

• Discuss recent executive action and other trade policy developments affecting global trade and tax compliance.
• Discuss the fundamentals of the U.S. import process and how the recent developments have impacted importing companies.
• Discuss the mechanisms utilized for managing risk and the financial impact of the disruption, including core trade (customs value, origin and classification) and other supply chain mechanisms deployed by companies.
• Analyze the interaction between customs valuation and transfer pricing and its impact on multinational tax planning.

3:15 PM – 4:30 PM | Employee Retention Credit: Overview, the OBBB Act Impact and ERC Litigation

The panel will provide a background on the employee retention credit and discuss the impact of the OBBB Act on the employee retention credit. Panelists will share the best practices of handling a variety of ERC issues through the IRS administrative process. Panelists will also give an overview of the current status of the ERC-related litigation.

• Moderator: Maryna Sticksel, Associate Attorney, McMahon & Tivnan, PC
• Patrick Cox, Partner, Nixon Peabody LLP
• Katherine Chace, Associated, Miller & Chevalier Chartered
• Morgan Nighan, Partner, Nixon Peabody LLP

Learning Objectives:

• Participants will be able to explain the statutory framework and evolution of the ERC, including key legislative acts and Internal Revenue Code provisions.
• Evaluate effective taxpayer and representative strategies for responding to IRS notices and disallowances related to ERC, preserving appeal rights, monitoring statutes of limitation, and managing compliance documentation.
• Participants will be able to choose the best strategy for ERC litigation as well as best practices for corporate due diligence.

Friday, March 6

10:00 AM – 11:15 AM | Developments on Penalty Litigation (The Seventh Amendment Right to a Jury Trial, Ethics, and Beyond)

The panel will discuss current developments on penalty litigation, with a particular focus on the taxpayer’s Seventh Amendment right to a jury trial in cases where the Internal Revenue Service wishes to impose a civil penalty.

• Moderator: Meeren Amin, Partner, Fox Rothschild LLP
• George Abney, Partner, Alston & Bird
• Sean McMahon, Shareholder, McMahon&Tivnan, PC
• Sanford J. Boxerman, Shareholder, Neill Schwerin Boxerman, P.C.
• Andrew Weiner, Counsel, Kostelanetz LLP

Learning Objectives:

• Understand the Court’s holding and analysis in Jarkesy regarding the Seventh Amendment’s right to a jury trial for certain administrative penalties
• Assess the potential impact of Jarkesy on IRS civil penalties, including which penalties may fall under Seventh Amendment protections
• Identify the arguments taxpayers and the Government may make regarding whether the Seventh Amendment creates the right to a jury trial and the status of cases relying on Jarkesy

11:45 AM – 1:00 PM | Stepping into the shoes of an energy project developer: What do purchasers of energy credits need to know before winning the IRS audit lottery?
This panel will introduce the audience to the most common energy tax credit and transferability statutes.  The panelists will discuss the issues facing taxpayers in energy credit examinations with a focus on potential difficulties for purchasers who may not have access to the books and records of the selling developer.  And the conversation will conclude with a look towards the future of energy tax controversy.

• Moderator: Brandon King, Attorney, Clean Energy Counsel, LLP
• Ted Lee, Senior Principal, Crux LLP
• Mary Kate Nicholson, Tax Attorney, Holland & Knight

Learning Objectives:

• Update attendees on the administration’s current priorities for energy credit guidance and availability of tax incentives
• Provide tools for attendees to effectively advise credit buyers and their counsel on how to identify common issues with energy project credit qualification
• Analyze potential pitfalls in credit transfer transactions from both a commercial and tax perspective
• Discuss current IRS enforcement trends for energy credit transfers

1:30 PM – 2:45 PM | Worth Your SALT: Constitutional Limitations and Current Controversies in State and Local Tax

State and local tax (SALT) often operates under the radar of federal practitioners—but it’s where some of the most consequential and unsettled tax issues arise. This session provides a “nuts and bolts” refresher on the fundamentals of SALT, including the constitutional limits on state taxing power, the structure of state income taxation, and the basics of sales and use tax. Panelists will also highlight key current developments—from economic nexus after Wayfair to battles over fair apportionment – and discuss how state revenue departments are testing the boundaries of their jurisdiction to tax.

• Moderator: Andrew Reiter, Senior Manager, Blue J
• Richard Jones, Partner, Sullivan & Worcester LLP
• Mathew Landwehr, Partner, Thompson Coburn LLP

Learning Objectives:

• Review key concepts of state corporate income tax and sales/use tax
• Understand the constitutional and federal limitations on state and local taxing authority
• Analyze state and local tax nexus, apportionment, and sourcing principles
• Identify current controversies and emerging issues in state and local taxation

3:15 PM – 4:30 PM | Pushing the Envelope: Developments in Permanent Establishment Risk and Digital Services Taxes
This panel will explore how the concept of permanent establishment is being redefined globally in response to digital business models, challenging traditional nexus standards. It will also examine the rise of digital services taxes as an alternative mechanism for taxing non-resident companies that generate significant revenue without a physical presence.

• Moderator: Brad Lombardi, International Tax Senior Manager, KLR
• Quyen Huynh, Principal, WNT International, KPMG LLP
• Joshua David Odintz, Partner, Holland & Knight

Learning Objectives:

• Analyze how evolving global standards are redefining permanent establishment (PE) in response to digital and e-commerce business models.
• Evaluate the use of digital services taxes, withholding regimes, and alternative nexus concepts adopted by the OECD, UN, and key non-OECD jurisdictions.
• Assess the practical implications of expanded PE risk and digital taxation developments for multinational tax planning, compliance, and dispute resolution.

If you have any questions regarding this program, please contact meetings@fedbar.org.