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Third Annual USD School of Law – RJS LAW Tax Controversy Institute


  • Friday, July 20, 2018 from 7:30 a.m. to 5:30 p.m.


  • Joan B. Kroc Institute for Peace and Justice, Theatre

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Event details

The USD School of Law- RJS LAW Tax Controversy Institute is the tax event of the year where the whole tax community comes together. During the day long conference, panelists will discuss topic including tax reform, alter ego assessments, criminal tax matters and international business and taxation. Additionally, the Institute will provide practical advice from top leaders in the tax field. It will also provide phenomenal networking opportunities to meet other top practitioners tax attorneys, CPAs, EAs and tax preparers.

The institute will feature two keynote speakers including; luncheon speaker- Chief Judge L. Paige Marvel, United States Tax Court and a prestigious individual for the evening keynote.

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During the evening reception the Richard Carpenter Excellence in Tax Award will be presented to Steven Toscher, Principal, Hochman, Salkin, Rettig, Toscher & Perez, P.C. Mr. Toscher, specializes his practice in civil and criminal tax litigation. Also, he is an Adjunct Professor at the University of Southern California, School of Accounting, where he teaches Federal Tax Procedure. Mr. Toscher is a Certified Tax Specialist in Taxation, the State Bar of California Board of Legal Specialization, a Fellow of the American College of Tax Counsel and has received an “AV” rating from Martindale Hubble. Prior to entering private practice, Mr. Toscher served as a Trial Attorney with the Tax Division of the United States Department of Justice, where he received its Outstanding Attorney Award. He is a summa cum laude graduate of the University of San Diego School of Law and a former Internal Revenue Agent. Mr. Toscher is a frequent lecturer and author on tax controversy topics, including FBAR and other international enforcement matters. In addition to his many periodical publications, he is a co-author of Tax Management’s “Tax Crimes” Portfolio.

Click here to view photos from the Second Annual USD School of Law – RJS LAW Tax Controversy Institute.

For more information or to register, click here to visit the USD School of Law- RJS LAW Tax Controversy Institute Webpage.


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The University of San Diego School of Law is a State Bar of California-approved MCLE provider. RJS LAW is a registered Continuing Education provider with the IRS and this event has been approved for 6.0 hours of IRS CE Credits.


Friday, July 20, 2018

7:30 – 8:30 AM

Continental Breakfast/ Registration

8:30 – 8:45 AM

Opening Remarks 

  • Miranda Perry Fleischer, Herzog Endowed Professor of Law; Co-Director of Tax Programs, University of San Diego School of Law
  • Ronson Shamoun, Principal Attorney & CEO RJS Law, Adjunct Professor of Law, University of San Diego School of Law
  • Debra A. Falcone, Taxpayer Advocate Service, Local Taxpayer Advocate

8:45 – 9:45 AM

Key Tax Challenges for International Businesses & Investors in California

In an increasingly globalized economy, taxpayers—from multinational corporations to globe-trotting individuals—can have financial dealings and information relevant to tax enforcement in many different countries. International agreements, including treaties, tax information exchange agreements, automatic exchange agreements, and local laws, dramatically affect whether and how information can be obtained and shared with other countries’ tax authorities. There are foreign developments in these areas that will affect California taxpayers investing internationally. Changes in foreign rules, including foreign tax credits and tax treaty changes, will lead to more differences internationally and likely more tax controversy disputes. Additionally, there are California tax developments that will also affect California taxpayer’s international taxes and investments.

  • John Forry, Managing Director at CBIZ, former partner at Ernst & Young (Moderator)
  • Paul Burns, CBIZ MHM, LLC
  • David Gill, International Tax Partner, Ernst & Young
  • Ricardo Cardenas, IRS Branch Chief, Office of Associate Chief Counsel (International)

9:50 –10:50 AM

Protecting Your Client Against the Issuance of a Summons and Summons Enforcement

One of the many investigatory tools the IRS has at their disposal is the issuance of summonses. With this tool the IRS can compel a taxpayer, as well as third parties, to appear and both provide testimony and produce documents.  Panelists will explore the different types of summons that can be issued in both civil and criminal cases, the scope of the summons power, and how the issuance of summonses can affect the statute of limitations on assessment.  Additionally, panelists will discuss how to handle summons appearances, including the assertion of privileges, dealing with third party summonses and the “nuts and bolts” of what happens if the IRS agent wants to seek enforcement of a summons because of a perceived failure to comply with the summons.

  • Lavar Taylor, Managing Partner at Law Offices of A. Lavar Taylor (Moderator)
  • Steven Walker, Principal at Law Offices of Steven Walker
  • Richard Carpenter, Principal at Richard Carpenter Tax Law Office
  • David J. Warner, Senior Attorney at IRS Office of Chief Counsel

10:50–11:00 AM


11:00–12:00 PM

Cannabis – Don’t Let Your Practice Go Up in Smoke

Laws regarding cannabis use and legalization are changing rapidly, leading to confusion for tax professionals on how to service cannabis business clients safely. Raise your awareness of the practice risks in today’s volatile legal environment.

  • Kaelyn Romey, Associate Professor of Law, Golden Gate University (Moderator)
  • Jonathan Kalinski, Hochman, Salkin, Rettig, Toscher & Perez, P.C.
  • Doug Youmans, Partner at Wagner, Kirkman, Blaine, Klomparens & Youmans LLP

12:00 – 1:35 PM


  • Introduction by Stephen C. Ferruolo, Dean and Professor of Law, University of San Diego School of Law
  • Keynote Speaker: Chief Judge L. Paige Marvel, United States Tax Court

1:35 – 1:45 PM


1:45 – 2:45 PM

Tax Reform – Big Changes, Big Planning Opportunities: What You Need to Know to Properly Advise Clients in 2018 and Beyond

Tax Reform is one of the hottest topics in the country right now. This panel will dive into some of the most significant proposals and explain how they may impact your clients and your practice. We’ll explore the closing of loopholes, reduced corporate and pass through tax rates, and the limitations to itemized deductions. We’ll also look at the U.S.’s move towards a territorial tax system and the phase out of the estate tax    

  • Howard Abrams, Professor of Law, Harvard Law School (Moderator)
  • Victor Fleischer, Director of Tax Programs & Professor of Law, University of San Diego School of Law
  • Frank Agostino, President, Agostino & Associates
  • Dr. Sarah Lyon, Professor, University of San Diego School of Business

2:45 – 2:55 PM


2:55 – 3:55 PM

Alter Ego, Successor In Interest and Nominee Liabilities: What They Are and The Best Tips on How to Limit Your Client’s Exposure

This panel will discuss third-party federal tax liens and what to do when the IRS tries to collect taxes that you do not owe. The panel will focus on the differences between nominee, transferee, successor, and alter-ego liability, the procedural safe-guards for third-party liability, discuss ways to protect against such liability, and how to deal with third-party IRS collections efforts.

  • Ronson J. Shamoun, Principal Attorney & CEO, RJS LAW, Adjunct Professor, University of San Diego School of Law (Moderator)
  • Michael Dallo, Principal Attorney, Dallo Law Group
  • Erin Salel, Associate Area Counsel, IRS Chief Counsel, SBSE
  • Laura Buckley, Partner, Higgs, Fletcher & Mack

4:00 – 5:30 PM

Criminal Tax Workshop: The Nuts & Bolts of Criminal Tax Representation

The Criminal Tax Workshop is a practical guide for handling sensitive civil examinations, criminal investigations, and defending criminal prosecutions. The distinguished panelists will address when to anticipate a criminal referral; how to handle IRS Special Agent interviews of taxpayers or tax preparers; how to effectively represent a target, subject or witness in a criminal investigation; how to approach a conference with the Department of Justice; procedural and trial issues that every criminal tax defense attorney should know; when and how to argue tax loss issues; effective plea negotiations; and strategies at employ at sentencing. Overall, this workshop will provide a “toolkit” of practice tips employed by experienced practitioners and government officials.

  • Steven Toscher, Principal, Hochman, Salkin, Rettig, Toscher & Perez, P.C. (Moderator)
  • Michael Lipman, Partner, Duane Morris’ Trial Practice Group
  • Martin Schainbaum, Founder, Martin A. Schainbaum PLC: Tax Warriors
  • Nathan Hochman, Partner, Morgan, Lewis & Bockius, LLP
  • John D. (Don) Fort, Chief, IRS Criminal Investigation
  • Philip Halpern, Assistant US Attorney, Southern District of California

5:30 – 9:00 PM

Celebrate & Connect! A Networking Opportunity Sponsored by Torrey Pines Bank

Come celebrate the day’s achievements and join us for cocktails and hors d’oeuvres while you connect with sponsors and other tax professionals!


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