K&F in the Classroom: International Tax Controversy at Georgetown Law

This spring, Caroline D. Ciraolo and Robert M. Russell have been bringing their decades of experience in federal tax enforcement and tax controversy matters to Georgetown University Law Center and Graduate Tax Program in a class entitled, “International Tax Controversy.”

Professors Ciraolo and Russell concentrate the course on real world civil and criminal tax controversies involving international tax matters facing today’s tax practitioners. Beginning with an introduction to the U.S. compliance regime — including the obligation to report worldwide income, specified foreign financial assets and international business activity — students learn the various international tax reporting obligations, applicable statutes of limitations and tolling provisions, potential civil penalties under the Internal Revenue Code and the Bank Secrecy Act, options for resolving non-compliance, procedures for challenging proposed and assessed penalties, and the risk and current landscape of criminal tax investigations and prosecutions. The course also includes a study of current international enforcement and litigation trends involving cross-border business transactions and base erosion/profit shifting issues.

Ms. Ciraolo previously served as Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division, where she was actively involved in all aspects of Tax Division operations and responsible for approximately 500 employees, including more than 360 attorneys in 14 civil, criminal and appellate sections. Ms. Ciraolo also teaches Criminal Tax Procedure at GULC, and the Investigation, Prosecution, and Defense of Tax Crimes at University of Baltimore School of Law Graduate Tax Program.

Mr. Russell developed broad experience in government enforcement, international tax planning and controversies, and tax policy during his tenures at the Internal Revenue Service, the Treasury Department, and Congress’ Joint Committee on Taxation.

Ms. Ciraolo and Mr. Russell also serve as supervising attorneys for Georgetown University Law Center’s LL.M. externship program. Students earn academic credit to join the Kostelanetz & Fink’s D.C. office for a semester to see the law in action while gaining a deeper understanding of real-world legal practices.

Kostelanetz & Fink is proud to be training the next generation of tax lawyers by sharing with  law students the important lessons they have learned from decades of representing a wide variety of corporations, institutions, and individuals in complex tax matters.