Caroline D. Ciraolo participated in a panel titled “From The Experts: IRS Representation Tools, Techniques, And Defensive Strategies – Civil & Criminal Tax Update” at the NYU 76th Institute on Federal Taxation

Tips from the tax trenches from leading tax controversy practitioners in an open discussion regarding pending IRS enforcement priorities and initiatives including the ongoing IRS Offshore Voluntary Disclosure Program / Streamlined Procedures re: FBARs and the Swiss Bank Program, effectively responding to IRS information document requests in the new enforcement environment, hot topics and enforcement priorities within the IRS Small Business and Self Employed Division and the IRS Large Business & International Division.

Other topics included new IRS Appeals procedures and resolution strategies; criminal tax enforcement update (foreign and domestic voluntary disclosures), current developments in the United States Tax Court; protecting privileged communications; penalty abatement considerations and recent cases of significance.