Caroline D. Ciraolo participated in a panel titled "The IRS And DOJ Continue To Prioritize Employment Tax Enforcement - Are You And Your Clients Prepared?" at the 2017 Annual Meeting of the California Tax Bar & California Tax Policy Conference

For the last several years, the IRS and the Department of Justice Tax Division have focused their attention on employment tax enforcement. We’ve seen new notices and alerts to taxpayers regarding non-compliance, more field visits by revenue officers, an increase in worker classification audits, a surge in suits for injunctions and motions for contempt, and an escalation of criminal investigations into willful employment tax violations.

Delinquent employers are facing heightened scrutiny at all levels, and are finding that outsourcing their obligations to staffing companies or professional employer organizations (PEOs) also presents new challenges. This panel engaged in a lively discussion of current civil and criminal employment tax enforcement statistics, recent developments and trends in this area, and best practices when representing employers and PEOs.


  • Caroline D. Ciraolo, Partner, Kostelanetz & Fink LLP
  • Darren John Guillot, Director, IRS Field Collection Operations
  • Noreene Stehlik, U.S. Department of Justice, Tax Division
  • Stephen Turanchik, Associate, Tax Department, Paul Hastings LLP