As tax season heats up, the Internal Revenue Service (IRS) is ramping up its digital solutions and data sharing to prevent crimes. 2019 promises to be a key year for the tax bar. With landmark administrative guidance in the wake of tax reform, practitioners will be contending with technological and legal developments that will have immediate and immense impacts. Join the Federal Bar Association Section on Taxation at the Ronald Reagan Building and International Trade Center in Washington, D.C. for the 43rd Annual Tax Law Conference on March 7-8, 2019. Register now at www.fedbar.org/taxlaw19 for this one and a half-day event!

The Federal Bar Association’s Tax Law Conference will explore a variety of tax-related concepts, including the use of technology in tax enforcement. Learn about the role of “big data” in the IRS’s and Department of Justice’s (DOJ) efforts to efficiently analyze the vast amounts of data that it receives from the Foreign Account Tax Compliance Act (FATCA), the former Offshore Voluntary Disclosure Program, the current Voluntary Disclosure Practice, the Swiss Bank Program, and Suspicious Activity Reports.

Attendees will also hear about the IRS’s and DOJ’s efforts to detect and pursue tax evasion through cryptocurrency, including the John Doe summons to Coinbase and the use of blockchain technology to track users’ transactions.

An all-star panel including moderator Jay R. Nanavati (Kostelanetz & Fink LLP), Don Fort (IRS Criminal Investigation), Allison Menkes (IRS Office of Chief Counsel), Jason H. Poole (U.S. Department of Justice), and Dennis L. Perez (Hochman Salkin Toscher Perez P.C.) will discuss the mechanisms through which the IRS and the DOJ can procure targets’ electronic communications, with an emphasis on the requirements of the Stored Communications Act of 1986.

In “The Blockchain Gang: Criminal Enforcement & Tax Reporting for Crypto,” panelists will tackle issues related to cryptocurrency. A blockchain is a digital ledger and can be designed to record any type of public or private transaction in real time. The most widely used public blockchains involve cryptocurrencies, such as Bitcoin. Blockchain can help the IRS lower costs and increase security, as well as enhance the speed in which it accesses and reviews taxpayer data. Blockchain is revolutionizing the way data is analyzed, exchanged, and stored.

The expert panel on blockchain technology includes moderator Stevie D. Conlon (Wolters Kluwer), Christopher Wajda (IRS Criminal Investigation), Steven T. Miller (alliantgroup), Michel R. Stein (Hochman, Salkin, Toscher, Perez P.C.), and Kevin F. Sweeney (Chamberlain, Hrdlicka, White, Williams & Aughtry).

Speakers will address cryptocurrency and tokens issued in coin offerings, which raise a variety of tax issues since their novelty and lack of guidance create tax reporting and related enforcement concerns. (Significant fluctuations in the value of coins and tokens and wide holdings exacerbate reporting and enforcement risks.) Attendees will learn about:

  • Existing IRS guidance on cryptocurrency and important open issues.
  • Tax issues giving rise to tax gains and losses on cryptocurrency and tokens, and potential recognition limitations and concerns.
  • Tax reporting and enforcement risks, as well as related IRS initiatives and statements regarding cryptocurrencies and ICO tokens.

Sign up today for the Tax Law Conference to explore the many moving parts of how technology is changing tax enforcement. Visit www.fedbar.org/taxlaw19 for more information about attending this essential tax law event. Ethics, CLE, and CPE credits are available.


Stacy Slotnick, Esq. holds a J.D., cum laude, from Touro Law Center and a B.A., summa cum laude, from the University of Massachusetts Amherst. She performs a broad range of duties as an entertainment lawyer, including drafting and negotiating contracts; addressing and litigating trademark, copyright, patent, and other IP issues; and directing the strategy and implementation of public relations, blogging, and social media campaigns.