18th Annual Tax Controversy Forum

Tax attorneys Abbey Garber, Amish Shah, Daniel Strickland and Chad Vanderhoef will participate in the New York University (NYU) School of Professional Studies' 18th Annual Tax Controversy Forum. Holland & Knight will serve as a sponsor of this yearly program, which unites government representatives and private practitioners to compare perspectives on topics involving federal tax audits, appeals and litigation.

Mr. Strickland will join a panel exploring the current landscape of Employee Retention Credit (ERC) claims, examining trends in audits, administrative appeals and pending litigation. He will also explain how to manage the risk for parallel proceedings and share best strategies for defending claims.

Mr. Vanderhoef's session will focus on offshore tax compliance, specifically Reports of Foreign Bank and Financial Accounts (FBARs). As the IRS continues to prioritize enforcement against U.S. taxpayers who fail to report their interests in foreign financial accounts in a timely or accurate manner, Mr. Vanderhoef will review Bank Secrecy Act examinations involving FBAR issues as well as debate how landmark court decisions on FBAR penalty assessments could change the IRS' entire approach in this field.

Mr. Shah will moderate a discussion on how to retain corporate and energy tax credits. Eligibility is only the first step in a process entailing careful planning from the outset. During this presentation, speakers will identify commonly pursued tax incentives and their qualifying thresholds, talk about IRS safe harbor compliance, review the life cycle of tax incentive controversies and recent court cases, and outline best practices for defending credits and safeguarding investments.

Finally, Mr. Garber will moderate a conversation on IRS administrative summonses and government subpoenas, which represent powerful investigative tools that can snare taxpayers and their advisors. Speakers will highlight the legal framework governing these requests along with common areas of disputes. They will also impart practical guidance for addressing risks and effectively advising clients when the government comes knocking.

Session Times and Topics

ERC: From Amended Returns to the Courtroom
June 25, 2026 | 10:45 a.m.
Speaker: Daniel Strickland

Is the Tide Finally Turning? Updated on FBAR Litigation
June 25, 2026 | 2:50 p.m.
Speaker: Chad Vanderfoef

Obtaining, Defending and Retaining Tax Credits
June 25, 2026 | 3:55 p.m.
Moderator: Amish Shah

When the Government Knocks: Responding to Summonses and Subpoenas
June 26, 2026 | 1:30 p.m.
Moderator: Abbey Garber