2026 Annual Tax Controversy Seminar & BBQ

Four (4) Free CLE, NASBA & Texas CPE, and EA & CTEC CE Credits

(available credits may vary by panel)

YOU MAY ONLY SIGN UP FOR ONE SEMINAR THAT YOU WILL ATTEND AND RECEIVE CREDIT FOR.

This panel explores the expanding role of technology in tax controversies, with a focus on artificial intelligence applications in tax dispute resolution and audit processes, integration of big data and emerging tech tools for tax professionals, the Tax Court's electronic courtroom including digital filing and virtual hearings through the DAWSON system, software demonstrations for filing Section 7508A (Kwong) claims, and ethical considerations in implementing technology in controversy work.

This panel examines alternative channels for tax support including community advocacy and digital tools, partnerships with non-profits and taxpayer advocate services, the role of media and public relations in tax controversies, and the role of the Office of Professional Responsibility (OPR) in supporting practitioners and taxpayers.

This panel addresses regulations, compliance, and ethical issues for tax preparers including Circular 230 standards and risk management, assertion and defense of preparer penalties, penalty avoidance and due diligence standards under IRC §6694, defenses against dishonest preparer penalties, criminal prosecution of preparers, impact of bad preparer conduct on statute of limitations and penalties asserted against taxpayers, malpractice claims and defenses, and sustainable practice building.

This panel focuses on the unique tax challenges facing entertainers, performers, digital influencers, and college athletes with Name, Image, and Likeness (NIL) deals.

This panel addresses recent changes in global tax reporting standards including FATCA and CRS, penalty structures and mitigation strategies, cross-border dispute resolution, BEPS Pillars I and II updates, case law update on assertion of penalties, voluntary disclosure programs for non-compliance, and international tax reporting for international students.

This panel covers trends in IRS criminal investigations and enforcement priorities, use of technology including AI in criminal tax investigations, case law developments and defenses against prosecution, collaboration with DOJ and other agencies on crypto and offshore evasion, and whistleblower impacts and emerging risks.

This panel covers IRS collection strategies and policies, installment agreements and offers in compromise, liens, levies, innocent spouse relief, collection due process hearings, and Section 7508A (Kwong) claims

Topics include BSA reporting obligations, FinCEN enforcement priorities and SAR filings, the Corporate Transparency Act and beneficial ownership reporting, cryptocurrency and digital asset AML, cross-border investigations with DOJ, gatekeeper obligations for attorneys, and emerging typologies.

Regional SALT issues including NY & NJ nexus rules, apportionment, recent case law, multi-state residency, post-Wayfair developments, and the role of state pro bono programs and LITCs in SALT cases.

This panel is organized as a four-panel track addressing the unique tax issues facing family offices across residency, planning, controversy, and criminal investigations. Each sub-panel runs approximately one hour.