Caroline D. Ciraolo participated in the panel titled "Fundamentals Of Tax Litigation: Choice Of Forum And Appealing Decisions" at the ABA Section of Taxation 2018 May Meeting
This panel discussed some of the basics of tax litigation; choosing a forum for litigating a tax dispute; and procedures for appealing decisions from the different trial forums. Panelists discussed jurisdictional requirements and limitations of the various courts, differences in discovery practice, trial procedure, drafting litigation documents, and procedures for appealing.
Caroline D. Ciraolo participated in the panel titled "Collection Of Title 31 International Penalties" at the ABA Section of Taxation 2018 May Meeting
With the increase in international enforcement efforts and heightened focus on anti-money laundering and anti-tax evasion, individuals and entities are finding themselves subject to substantial civil penalties for failing to report foreign financial accounts and other violations of the Bank Secrecy Act. This panel reviewed the Title 31 civil penalties, the methods by which the United States can collect such penalties, available defenses, and best practices for pursuing collection alternatives.
Caroline D. Ciraolo participated in the panel titled "The Gathering Storm: Grappling With The Impact Of Restitution Orders On Civil Tax Litigation" at the ABA Section of Taxation 2018 May Meeting
In criminal cases involving tax counts, defendants being sentenced frequently wish to show remorse by paying the criminal tax loss prior to sentencing. These payments generally predate any actual civil tax determinations, let alone an IRS assessment. To allow the IRS to assess and collect an amount of restitution as if such amount were tax, Congress, in 2010, amended section 6201(a)(4). The result was that sentencing district court judges could now issue Restitution Orders permitting immediate assessment of the tax loss amount by IRS.
Caroline D. Ciraolo published in "The IRS Is Taking Off Its Velvet Gloves For Offshore Holdings", Accounting Today
Ferreting out people who want to hide their assets and income overseas is nothing new for the Internal Revenue Service. And for roughly nine years, the agency has sponsored programs tailored to those taxpayers who were prepared to come forward and disclose their unreported foreign assets and income in exchange for reduced penalties and the promise that they would not be prosecuted.