Michael Desmond, Rocco Femia, and George Hani will speak at the Texas Federal Tax Institute on June 3, 2026. Desmond will serve as Program Moderator for the tax controversy section and moderate a "Fireside Chat with Erin Collins, National Taxpayer Advocate." This discussion will include an overview of the Taxpayer Assistance and Service Act, which was recently formally introduced in the United States Senate.

Femia will speak on the panel "Significant Developments in Transfer Pricing: 3M, Facebook, Perrigo, Medtronic, and Eaton." This panel will discuss the transfer pricing decisions have been issued by the U.S. Tax Court, U.S. District Courts, and the U.S. Courts of Appeal in the past year. They will discuss the key cases and provide practical takeaways and lessons learned and consider how these decisions are changing current practices related to transfer pricing documentation, intercompany pricing approaches, and audit readiness, and what these decisions mean for taxpayers from both a planning and controversy perspective.

Hani will co-present "Defending Internal Revenue Service Accounting Method Challenges." The Internal Revenue Service (IRS) is intensifying its use of accounting method challenges to collect tax in years where assessment is barred by the statute of limitations. This panel will explore the scope of this powerful tool, how the IRS deploys accounting method challenges, and the issue of what does (and does not) constitute an accounting method change. Panelists will survey the relevant case law and administrative guidance and discuss strategies for resolving accounting method challenges in IRS Appeals.