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

Thursday, March 5

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.

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.

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, exploring 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.

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.

Friday, March 6

10:00 AM – 11:15 AM | Developments on Penalty Litigation (The Seventh Amendment Right to a Jury Trial 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.

11:45 AM – 1:00 PM | Energy Credits 

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.

12:30 PM – 1:30 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.

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