Caroline D. Ciraolo and Robert Russell Participated on the Panel "What Every Estate Planner Needs to Know About International Tax and Reporting and the Government's Enforcement and Initiatives" at the 2019 Meeting of the California Tax Bar
Caroline D. Ciraolo and Robert Russell participated on the panel "What Every Estate Planner Needs to Know About International Tax and Reporting, and the Government's Enforcement and Initiatives" at the 2019 Annual Meeting of the California Tax Bar & California Tax Policy Conference in San Diego, CA.
Caroline D. Ciraolo Participated in a Panel Entitled "IRS Voluntary Disclosure Program and Updates on the Other Offshore Procedures" at the 56th Annual Hawaii Tax Institute on November 5, 2019
An analysis of the new and updated IRS voluntary disclosure program which covers
domestic and foreign cases. Also included will be an update of the other offshore
procedures (Streamlined Domestic Offshore Procedures, Delinquent Procedures
for FBARs, and International Forms); hands on practical advise on how the IRS
administers these programs; and how to get your clients through the process.
Caroline D. Ciraolo Participated in the Panel Entitled "Caution Trustees - Beware of Unresolved Tax Liabilities of Incapacitated Taxpayers and Decedents; Ethical Considerations" at the Hawaii Tax Institute on November 4, 2019
Fiduciaries need to be aware of the potential for personal liability if distributions
are made to beneficiaries prior to fully satisfying tax liabilities of an incapacitated
taxpayer or decedent. Under 37 USC section 3713, known as the “Federal Priority
Act,” a fiduciary may be held personally liable for any distribution in contravention of the Federal Priority Act if the incapacitated or deceased taxpayer (i) failed
to file any tax return, (ii) failed to pay any tax, interest or penalties, or (iii) filed
inaccurate or incomplete tax returns. This session will discuss the Federal Priority
Act, actions that the fiduciary may consider taking to minimize its application, how
probate courts address these issues, ethical considerations, and what efforts can
be made to enable the fiduciary to receive a full release of personal liability.
Caroline D. Ciraolo Participated as a Keynote Speaker in the Seminar "Paying U.S. Taxes in Canada: Are you caught on the borderline?" on November 2, 2019
Are you a U.S. Citizen, Green Card holder, born on U.S. soil or born abroad to a U.S. parent and live in Canada? Do you have financial accounts in Canada or anywhere outside of the U.S.? If you have never filed U.S. tax returns or are behind on annual tax filings or reporting financial accounts, you could be subject to significant penalties up to $10,000 (USD) per account, per year unreported.
Caroline Ciraolo Spoke on the Panel Entitled "International Enforcement - What’s Old, What’s New and What We Can Expect," at the 35th Annual Tax Controversy Institute on October 22, 2019
The Annual Tax Controversy Conference is the preeminent conference exclusively dedicated to tax controversy and tax litigation. The conference provides an open forum for distinguished presenters and panelists to discuss, and often debate, sensitive tax practice issues with an engaged audience.