Ms. Ciraolo delivered a presentation as part of the IRS Office of Chief Counsel Lecture Series.
Caroline D. Ciraolo presented "A Perspective on IRS Virtual Currency Enforcement Action" at the Blockchain, Accounting, Audit & Tax Conference
This panel focused on recent IRS enforcement activities including the use of John Doe summons to get expansive customer records from a virtual currency exchange. John Doe summons are generally used to obtain information when specific taxpayers cannot be identified in an investigation.
Caroline D. Ciraolo spoke on the panel "Tax Compliance and Enforcement Update Part II - Department of Justice Update" at the 9th Annual NYU Tax Controversy Forum
Voluntary compliance and enforcement of the tax law are at the heart of our tax system. Over the past several years, the IRS and DOJ have been challenged to come up with new and more efficient ways to ensure that all taxpayers pay the correct amount of tax. This panel provided an update on new developments and priorities across the IRS and DOJ.
Caroline D. Ciraolo moderated the panel "International Exchange of Information and Evidence Gathering" at the 9th Annual NYU Tax Controversy Forum
In an increasingly globalized economy, taxpayers—from multinational corporations to globe-trotting individuals—can have financial dealings and information relevant to tax enforcement in many different countries. International agreements, including treaties, tax information exchange agreements, automatic exchange agreements, and local laws, dramatically affect whether and how information can be obtained and shared with other countries’ tax authorities. This panel examined the various methods that are used and issues that arise when one country’s tax authorities seek information and evidence within the jurisdiction of another country.
Caroline D. Ciraolo spoke on the panel "Tax Enforcement Update: Significant Issues" at the 33rd Annual Texas Federal Tax Institute
This event consisted of a lively discussion among former high ranking government representatives (including a former IRS Commissioner, IRS Chief Counsel, and Acting Assistant Attorney General [Tax]) with the IRS Associate Chief Counsel (Procedures and Administration) and IRS Area Counsel (SB/SE) regarding current IRS enforcement issues in an era of budget cutbacks and tax policy and enforcement challenges.
Caroline D. Ciraolo presented "Coming Attractions in Tax Controversies" at the 2017 IRS Tax Problem Resolution Spring Conference
When was the last time you had the chance to gaze into the crystal ball housing the IRS playbook? Never, Right? Caroline Ciraolo joined us in San Antonio fresh from DOJ. She has resigned her position with DOJ and joined us in representing taxpayers before the IRS. This event was a unique opportunity to learn the DOJ perspective on tax administration and enforcement.
On Aug. 29, 2013, the Department of Justice announced the Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks.1 Between March 30, 2015, and Jan. 27, 2016, the DOJ entered into 78 non-prosecution agreements with a total of 80 Swiss banks, collecting more than $1.3 billion in penalties, getting a trove of information regarding accounts related to U.S. taxpayers, and ensuring the cooperation of participating banks.