Caroline D. Ciraolo participated in a panel titled "Cross Border Individual Matters" at the 30th Annual Institute on Current Issues in International Taxation

This panel discussed topics flowing from recent global cooperation (FATCA/CRS) and enforcement by US tax authorities.

The topics included:

  • Immigration and expatriation – planning, strategies, residency, and estate issues.
  • High-level summary of offshore enforcement activities (OVDP/streamline numbers, current issues in streamline submissions). 
  • FBAR developments – audit/appeals/litigation activity.
  • Civil offshore enforcement tools and increased cooperation among foreign jurisdictions.
  • Criminal offshore enforcement update (current statistical information; focus on “leaver” cases from Swiss Bank Program; and sentencing data).


Mark E. Matthews, 
Partner, Caplin & Drysdale, Washington, DC


Caroline D. Ciraolo, 
Partner, Kostelanetz & Fink, LLP, Washington, DC

Amanda P. Varma, Partner, Steptoe & Johnson LLP, Washington, DC

Lowell D. Yoder, Partner, McDermott Will & Emery LLP, Chicago, IL

Natalia Velez, International Tax Partner, MGO LLP, Los Angeles, CA

John Cardone, Director, Withholding and International Individual Compliance, LB&I, Internal Revenue Service, Washington, DC