Dan is a frequent speaker at continuing legal education events across North America. The following list summarizes a few of his speaking engagements in recent years, many of which resulted in press coverage in Tax Notes and other publications. Presentation materials are hyperlinked below for select presentations.

• STEP Hong Kong (Webinar 2/28/2024). Topic: "United States – Internal Revenue Service - International Information Return Penalties, Recent Litigation, and Penalty Strategies"

• University of San Diego School of Law – Chamberlain International Tax Institute (Merida, Mexico 2/20/2024). Topic: "International Collection"

• International Information Return Penalties, Recent Litigation, and Penalty Strategies

• Florida Bar Tax Section’s 42nd Annual International Tax Conference (Miami, FL 1/19/2024). Topic: "Dealing with IRS International Information Return Penalties and Avoiding Malpractice Claims that Could Ruin Both You and Your Firm"

• The University of Texas 71st Annual Taxation Conference (Austin, TX, 12/13/2023). Topic: "Penalty Strategies that Work"

• ABA Criminal Tax Fraud/Tax Controversy 2023 (Las Vegas, NV 12/9/2023). Topic: "Employee Retention Credit: Civil and Criminal Enforcement"

• 82nd Annual NYU Institute on Federal Taxation (Berkeley, CA 11/12/2023). Topic: "From the Experts: Tax Controversy and Tax Litigation – Civil & Criminal Tax Update"

• TXCPA Austin Annual Tax Conference (Austin, TX 11/6/2023). Topic: "Effectively Using FOIA in Your Tax Practice"

• 15th Annual NYU Tax Controversy Forum (New York, NY 6/9/2023). Topic: "Recent Developments Affecting International Reporting Penalties"

• 18th Annual Procopio International Tax Institute (San Diego 5/25/2023). Topic: "What to do when Advisors Find Errors in International Tax Returns"

• University of San Diego School of Law – Chamberlain Hrdlicka International Tax Institute (Mexico City 5/5/2023). Topic: "The IRS’ Powers and Practices in Collecting International Records and Evidence in Civil and Criminal Investigations"

• International Fiscal Association USA Branch Annual Meeting (Chicago, IL 4/28/2023). Topic: "Avoiding and Contesting IRS Penalties"

• ABA Tax Section Mid-Year Meeting (San Diego, CA 2/10/2023). Topic: “From the Cradle to the Graev: What is next for section 6751(b)?”

• Florida Bar Tax Section’s 41st Annual International Tax Conference (Miami, FL 1/13/2023). Topic: “International Information Returns: Trends and Strategies”

• The Freeman Law International Tax Symposium (virtual 10/21/2022). Topic: “International Information Reporting: Challenges and Strategies”

• UCLA’s 38th Annual Tax Controversy Institute (Beverly Hills, CA, 10/27/2022). Topic: “How to Resolve Your Cases at IRS Appeals Including Cases Docketed Before the Tax Court”

• Texas Federal Tax Institute 2022 (San Antonio, TX, 6/8/2022). Topic: “Current IRS Enforcement with Focus on International”

• DC Bar Communities webinar (virtual 6/30/2022). Topic: “Tax Litigation Update: The Latest on FBAR and Other International Information Return Penalties”

• 14th Annual NYU Tax Controversy Forum (New York, NY, 6/24/2022). Topic: “Coming in From the Cold: The Future of Voluntary Disclosures”

• Agostino & Associates webinar (virtual 6/15/2022). Topic: “Tax Compliance for Refugees”

• Texas Federal Tax Institute 2022 (San Antonio, TX, 6/8/2022). Topics: “Current IRS Enforcement with Focus on International” and “International Information Returns for Individuals: Proceed with Caution”

• San Francisco Tax Club (virtual 2/3/2022). Topic: “Hot Topics in International Penalties”

• The Freeman Law International Tax Symposium (virtual 11/18/2021). Topic: “Voluntary Disclosures”

• American Bar Association webinar (9/9/2021). Topic: “Compliance Initiatives and Voluntary Disclosure Practice—Perspectives and Updates from Puerto Rico's Hacienda and the IRS”

• The  37th Annual UCLA Tax Controversy Institute (10/21/2021). Topic: “IRS Voluntary Disclosure Practice”

• The 2021 State Bar of Texas Advanced Tax Law CLE (8/20/2021). Topic: “Voluntary Disclosure Practice 2021 and Beyond”

• American Bar Association webinar (11/18/2020). Topic: “Coming in from the Cold—Risks and Rewards of the Revised IRS Voluntary Disclosure Practice”

• AICPA webinar “20:20 View of International Tax—Part II” (11/17/2020)

• Florida Bar Tax Section’s 38th Annual International Tax Conference (Miami, FL, 1/17/2020). Topic: “Compliance Options in a Post-OVDP World”

• The University of Texas 67th Annual Taxation Conference (Austin, TX, 12/4/2019). Topic: “Voluntary Disclosure Practice and Hot Topics in IRS Enforcement”

• The 22nd Annual Texas State Bar International Tax Symposium (Houston, TX, 11/21/2019). Topics: “Relief Procedures for Certain Former Citizens” and “Offshore Compliance Update”

• The 2019 University of San Diego School of Law—Procopio International Tax Institute (San Diego, CA, 11/18/2019). Topics: “IRS Relief for Current and Former U.S. Citizens Overseas ‘Expatriation’” and “IRS International Tax Enforcement in a Post OVDP World”

• California Lawyers Association 2019 Annual Tax Meeting (San Diego, CA, 11/8/2019). Topic: “What Do You Mean There Is a $10,000 Penalty?”

• Hawaii Tax Institute (Honolulu, HI, 11/4 – 11/5/2019). Topics: “Caution Trustees: Beware of Unresolved Tax Liabilities of Incapacitated Taxpayers and Decedents” and a presentation on offshore compliance options  

• IRS Webinar with transcript posted to IRSvideos.gov on “Relief Procedures for Certain Former Citizens” (Washington, D.C., 10/10/2019).

• Texas Federal Tax Institute 2019 (San Antonio, TX, 6/12/2019). Topic: “Hot Topics in International Enforcement and Controversies”

• University of San Diego School of Law—International Outreach (Mexico City, Mexico, 5/23/2019). Topic: “U.S. Citizens Living in Mexico and U.S. Tax Law”

• ABA 35th National Institute on Criminal Tax Fraud and Eighth Annual National Institute on Tax Controversy (Las Vegas, NV, 12/14/2018). Topics: “Ethical and Other Issues When Representing Non-Compliant Taxpayers: Domestic and Foreign Voluntary Disclosures in a Post-Program World” and “Litigating Foreign-Related Penalties”

• California Society of CPAs (Burbank, CA, 11/15/2018). Topic: “Offshore Compliance Options and Issues”

• Texas State Bar International Tax Symposium (Houston, TX, 11/8-11/9/2018). Topics: “Compliance Options Offered by the IRS” and “Government Priorities Panel”

• The 2018 University of San Diego School of Law—Procopio International Tax Institute (San Diego, CA, 11/1/2018). Topic: “Offshore Compliance Options and Issues”

• ABA Tax Section Mid-Year Meeting (Atlanta, GA, 10/6/2018). Topic: “OVDP—End of an ERA”

• The 2018 State Bar of Texas Annual Meeting (Houston, TX, 6/22/2018)

• Texas Federal Tax Institute 2018 (San Antonio, TX, 6/6/2018). Topic: “International Tax Enforcement and Offshore Reporting”

• Florida Bar Tax Section’s 36th Annual International Tax Conference (Miami, FL, 1/12/2018). Topic: “Panel on Miscellaneous Civil and Criminal Procedural Issues”

• The 20th Annual International Tax Symposium (Dallas & Houston, TX, 11/2/2017 & 11/3/2017). Topic: “Offshore Voluntary Disclosure Program/Streamlined Compliance Update”

• The 2017 University of San Diego School of Law—Procopio International Tax Institute (San Diego, CA, 10/26/2017)

• Canadian Tax Foundation (Montreal, Canada, 9/20/2017). Topic: “Offshore Compliance Options including the Streamlined Filing Compliance Procedures”

• The 2017 State Bar of Texas Advanced Tax Law CLE (Houston, TX, 8/17/2017)

• Chief Counsel “SB/SE & LB&I Tax Roundup” CLE (Dallas, TX, 8/22/2017). Topic: “International Hot Topics.” IRS and Chief Counsel personnel only.

• PLI - International Estate & Tax Planning 2017 (New York, NY 5/22/2017). Topic: "Compliance and Criminal Enforcement Options for Noncompliant International Taxpayers"

• Florida Bar Tax Section’s 35th Annual International Tax Conference (Miami, FL, 1/6/2017). Topic: “Panel on Miscellaneous Civil and Criminal Procedural Issues”

• Canadian Tax Foundation’s 68th Annual Tax Conference (Calgary, Canada, 11/28/2016)

• The 19th Annual International Tax Symposium (Dallas & Houston, TX, 11/3/2016 & 11/4/2016)

• The 2016 State Bar of Texas Advanced Tax Law CLE (Austin, TX, 10/26/2016). Topic: “Getting International Returns Right the First Time”

• California Society of CPAs (San Diego, CA, 10/18/2016)

• Society of Trust and Estate Practitioners’ 18th Annual Meeting (Toronto, Canada, 6/9/2016)

• The 2016 State Bar of Texas Annual Meeting (Fort Worth, TX, 6/17/2016). Topic: “IRS Enforcement Update” focusing on offshore compliance issues

• IRS webcast with transcript posted to IRSvideos.gov (recorded in Washington, D.C., 5/11/2016). Topic: “Streamlined Filing Compliance Procedures—A Compliance Option for Some Taxpayers”

 

 

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