We are proud to share that Sandra R. Brown and Evan J. Davis will be speaking on the following topics at the Hawaii Tax Institute’s 63rd Annual In-Person Conference, taking place November 15-19, 2026, at the Hilton Hawaiian Village Waikiki Beach Resort.
Taxpayer Privacy: Understanding the Political, Ethical and Legal Landscape of Disclosures of Confidential Taxpayer Information
Monday, November 16th – 6:30 a.m. – 7:30 a.m.
Sandra along with Evan and Lisa M. Piehl (Former Program Manager, IRS Estate and Gift Tax Policy Division) will discuss a major 2026 focus on the legal battle over a data-sharing agreement between the IRS and Immigration and Customs Enforcement (ICE).
DOJ and IRS Enforcement Objectives Relatives to High Net Worth Individuals and Ethical Considerations
Tuesday, November 17th – 6:30 a.m. – 7:30 a.m.
Evan along with Kenneth Hines and Victor Song of Integritas will discuss how FinCEN, DOJ, and IRS Criminal Investigations are working together to target their enforcement efforts. This session will discuss the current IRS operating environment and enforcement priorities, foreign cooperation, together with trends, ethical considerations and recent developments in tax litigation within DOJ.
Beyond the IRS: Nonprofit Strategies to Address Heightened Scrutiny from the Newly Created DOJ National Fraud Enforcement Division and Ethical Considerations
Tuesday, November 17th – 1:30 p.m. – 2:30 p.m.
Sandra along with Meghan Biss (Loeb & Loeb LLP) and Ofer Lion (Seyfarth Shaw LLP) will discuss how exempt organizations (EOs), such as charities and nonprofits, are subject to both civil and criminal enforcement by the IRS when they violate tax laws, engage in private inurement, or abuse their tax-exempt status.
A Peek into Gift and Estate Tax Valuations: Behind the Scenes Analysis and Practical Applications
Wednesday November 18th – 1:30 p.m. to 2:30 p.m.
Evan along with Dean Colvin (Cabrillo Advisors) and Christina Dawson (Nutter, McClennen & Fish, LLP) will explore IRS rules and requirements for a proper valuation report involving valuation for gifting and charitable contributions, estate non-taxable and taxable situations, and ownership transfers.
Crisis Management in the Era of AI and Social Media: Ethics and Communications Lessons from the IRS
Thursday, November 19th – 9:00 a.m. – 10:00 a.m.
Evan along with Sharyn Fisk (Former Director, IRS Office of Professional Responsibility) and Terry Lemons (Former IRS Chief of Communications) will discuss the growing threat from the rapid changes taking place across the communications and ethics landscape. When AI tools enter the practice, what do professional ethics obligations actually require and how do you protect your firm?
This year’s program focuses on current, practical topics, outstanding education and professional development, led by a distinguished faculty. The Institute is designed as a forum where people working in tax and wealth transfer can exchange ideas about real-world challenges.
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Sandra R. Brown is a Principal of Hochman Salkin Toscher Perez P.C., where her practice focuses on criminal tax investigations, grand jury matters, litigation, and sentencing matters as well as representing and advising taxpayers involved in complex and sophisticated civil tax controversies, including sensitive-issue audits and administrative appeals and litigation. Ms. Brown’s extensive experience and successes have included many notable cases including two U.S. Supreme Court decisions, numerous 9th Circuit rulings and numerous favorable administrative resolutions for taxpayers involved in IRS investigations and audits. Prior to joining the firm in 2018, Ms. Brown served as the Acting United States Attorney, First Assistant United States Attorney, and Chief of the Tax Division in the Office of the U.S. Attorney, Central District of California; where, with 27 years as a trial lawyer, she personally litigated over 2,000 tax cases.
For more information, please contact Sandra R. Brown at brown@taxlitigator.com.
Evan J. Davis has been a principal at Hochman Salkin Toscher Perez P.C. since November 2016. He spent 7.5 years as a DOJ Tax civil litigator and then 11 years as a criminal AUSA in the Office of the U.S. Attorney (C.D. Cal), including 3 years handling civil and criminal tax cases and 8 years as a white-collar prosecutor handling tax and other fraud cases from investigation through jury trial and appeal. As an AUSA, he served as the Bankruptcy Fraud coordinator, Financial Institution Fraud coordinator, and Securities Fraud coordinator. Mr. Davis handles federal and state criminal and civil tax investigations/exams, white-collar defense, cryptocurrency clients, and civil and criminal appellate matters including having litigated the In re Grand Jury attorney-client privilege matter before the U.S. Supreme Court in 2023.
For more information, please contact Evan J. Davis at davis@taxlitigator.com.
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