Broadcast Date: Wednesday, October 11, 2023
from 12:00 pm to 1:30 pm (ET)


Tax controversy is as a major concern of businesses across industries primarily due to intensified scrutiny on tax avoidance practices. As the market rapidly evolves, tax disputes are becoming more prevalent both domestically and globally, posing significant challenges for multinational companies. These companies often find themselves entangled in tax disputes across different jurisdictions, placing a considerable strain on their resources.

In today’s ever-changing tax landscape, new sources of controversy continue to surface along with the stringent tax laws. This dynamic environment makes it more critical for businesses to be wary of their existing practices to mitigate tax controversies.

In a LIVE Webcast, a panel of thought leaders and practitioners assembled by The Knowledge Group will discuss the recent and significant tax controversies. The speakers will provide best approaches on how to effectively navigate the complexities of tax disputes and safeguard their financial stability.

Key issues include:

  • Top Tax Controversy Cases: Recent Trends
  • Impacts of Major Cases
  • Significant Issues and Challenges
  • How to Manage Tax Controversies
  • Best Strategies to Prevent and Resolve Disputes

Learning Objectives:

  • Identify key areas of concern and targets within tax enforcement, including large partnerships, corporations, high-income individuals, and emerging issues such as cryptocurrency.
  • Recognize recent trends and developments in tax controversies, including audit rate fluctuations, enforcement priorities, and the evolving landscape of state and local tax disputes.


Course Level:



Advance Preparation:

Print and review course materials


Method of Presentation:

On-Demand Webcast



General knowledge of tax laws


Course Code:



NY Category of CLE Credit:

Areas of Professional Practice


NASBA Field of Study:

Taxes – Technical


Total Credits:

1.5 CLE

1.5 CPE (Not eligible for QAS (On-demand) CPE credit)

Speaker Panel:

W. Curtis Elliott, Jr., Partner
Culp Elliott & Carpenter P.L.L.C.

Curtis Elliott is one of the leading tax litigators in the United States. He has over 30 years of experience litigating civil and criminal tax cases, including IRS audits and appeals, and grand jury proceedings. He has extensive courtroom trial experience in the U.S. Tax Court, the Federal District Courts and state courts. His tax advocacy has resolved some of the most complex, high-stakes tax cases for clients. Mr. Elliott’s clients include Fortune 500 companies, entrepreneurial companies, estates, and individuals. He works closely with co-counsel and CPA firms. Mr. Elliott is a Fellow in the American College of Tax Counsel and is very active in the ABA Section of Taxation. He speaks at conferences across the country on tax dispute topics.

Shannon Retzke Smith, Partner
Withers Bergman LLP

Shannon is a partner at Withers Bergman LLP.

She focuses her practice on sensitive tax matters, which often involve negotiations with government agencies. Shannon represents clients in a broad range of tax, trust, estate, and business planning issues. Her work involves planning for high net worth US and international families, with particular emphasis on planning for closely-held businesses. Shannon’s planning work for clients involves a range of matters, from creating tax-efficient wealth transfer structures to addressing income tax issues arising from investments and operating businesses. She has advised prominent politicians, business people, and well-known athletes. She is known globally as one of the go-to attorneys for individuals with US tax or reporting issues and has represented clients from over 20 countries in the last year.

Michael Steffany, Senior Attorney
Withers Bergman LLP

Michael is a senior attorney at Withers Bergman LLP.

His practice focuses on domestic and international tax planning, compliance, and controversy resolution for individuals and closely held businesses.


W. Curtis Elliott, Jr.Partner

Culp Elliott & Carpenter P.L.L.C.

Shannon Retzke SmithPartner

Withers Bergman LLP


Michael SteffanySenior Attorney

Withers Bergman LLP

  • Additional funding on enforcement
  • Trends in audit rate Past/Present
  • Four top targets Slide:
    • Large partnerships
    • Large corps
    • High income individual
    • High net worth individuals
  • FBAR / HNW audits
  • Analytics to aid in audit selections
  • More details about expanded enforcement for large corporations
  • Employee Retention Credit Audit
  • Focus on Trusts
  • Focus on Conservation Easements
  • Focus on Micro Captives
  • Focus on Malta Pension
  • Focus on Puerto Rico residency audits
  • Tax Exempts
  • Cryptocurrency
  • Trends in State / Local Controversy
  • Focus on Monetized Installment Sales
  • Civil Tax Penalty Recent Developments – Whose Burden of Proof and Substantive Defenses
  • Other Hot Cases (If time permits)

Date & Time:

Wednesday, October 11, 2023

12:00 pm to 1:30 pm (ET)

Who Should Attend:

  • Tax Lawyers
  • Tax Consultants
  • Tax Accountants
  • Tax Managers
  • Tax Supervisors
  • Tax Compliance Officers
  • Tax Specialists/Analysts
  • Tax Supervisors
  • Tax Practitioners and Professionals
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W. Curtis Elliott, Jr.Partner
Culp Elliott & Carpenter P.L.L.C.
Shannon Retzke SmithPartner
Withers Bergman LLP
Michael SteffanySenior Attorney
Withers Bergman LLP



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