Attorney Client and Work Product Protections – Increasing Limitations in the Digital Age (Criminal Law Symposium 2026 session)

For more than thirty-five years, Bryan C. Skarlatos has represented corporations and individuals in sensitive matters, many of which involve negotiation or litigation with government agencies. He is internationally recognized for his work on tax controversies, audits, appeals and litigation, criminal tax investigations, and white-collar criminal prosecutions. Bryan also has an active practice providing tax and estate planning advice. Bryan is often retained to evaluate the strength of tax positions for tax and financial reporting purposes and to advise on potential remedial actions. He counsels corporations and individuals from around the world on how to come into compliance with U.S. tax law, and he has handled hundreds of voluntary disclosures involving both domestic income and foreign assets. Bryan is an adjunct professor at New York University School of Law where he teaches a course on tax penalties, and he created and co-chairs the annual New York University Tax Controversy Forum, which brings together representatives from the government and expert private practitioners to discuss issues related to tax compliance and enforcement. Bryan has been hired by foreign and state governments, and several other clients, to provide expert testimony on tax penalties. He has testified before the U.S. House of Representatives Ways and Means Committee as an authority on tax penalties, and he has testified before the Internal Revenue Service regarding the IRS whistleblower law. Bryan was retained by Senator Charles Grassley, the drafter of the IRS whistleblower law, to write an amicus brief on behalf of the Senator in the D.C. Circuit Court of Appeals. Chambers and Partners has ranked Bryan in its top tier of lawyers in the U.S. for Tax Fraud in its USA Guide and for Tax: Private Client in the agency’s High Net Worth Guide. Chambers USA Guide has described Bryan as having a “smart reassuring presence with insight into the government….[He is] extremely knowledgeable and very well connected to the various tax authorities.” The High Net Worth Guide notes that Bryan “is a brilliant lawyer,” “has a ton of experience,” “has excellent judgment,” and “is very pragmatic and very dedicated to his clients.” He also has been recognized by Super Lawyers as one of the Top 100 Lawyers in New York, and Best Lawyers in America has named Bryan “Lawyer of the Year” for Tax Litigation in New York three times.

Ian has more than 35 years of experience representing corporations and individuals in civil and criminal tax litigation, white-collar criminal defense, and complex corporate and commercial disputes. His experience includes: tax controversy work such as IRS administrative and grand jury investigations, Tax Court, Claims Court and District Court trials and appeals, jeopardy and termination assessments, responsible officer penalty and collection matters; corporate compliance matters involving the Bank Secrecy Act and USA PATRIOT Act and FATCA issues for financial institutions including banks, broker-dealers and mutual funds; commercial litigation focused on accounting and legal malpractice cases as well as securities and class action matters, all involving tax and related accounting issues; and corporate internal investigations for financial institutions and other entities, including claims under the Foreign Corrupt Practices Act. Prior to joining Fox, Ian was co-chair of the white-collar practice at Blank Rome for more than three decades. Before that, he was an assistant district attorney in Philadelphia County, a special assistant U.S. attorney and an assistant U.S. attorney in the Southern District of Florida. Ian serves as special projects chair of the American Bar Association Tax Section. He is a member of the Board of Governors of the Florida Bar, where he serves as chair of the Investment Committee. Ian also serves on the boards of directors of the Citizens Crime Commission of the Delaware Valley, Historic Philadelphia, Inc. and the Madlyn and Leonard Abramson Center for Jewish Life. He is also the secretary and a member of the board of directors of the Mann Center for the Performing Arts. Additionally, Ian is a member of the Brandeis Society, the Pennsylvania Horticultural Society, the Philadelphia Museum of Art and the Franklin Institute, among other local organizations. Ian is the co-author of the two-volume treatise Tax Fraud and Evasion, has appeared on CNBC’s Money Talk and CNN and is called upon frequently to comment on tax issues. He was elected in 1995 to the American College of Tax Counsel and is an adjunct professor at the University of Pennsylvania Law School.