Tax Notes Today turned to Kostelanetz & Fink partner Caroline D. Ciraolo for comment on solutions to the underrepresentation of women in tax professions. 

In considering how to better discourage and control economic crime we examined the real threats facing our economies and, in particular, those who look after other people’s wealth not just from criminals and terrorists, but also indirectly as a result of law enforcement and regulatory intervention. We also contexted these risks and the responses not only in terms of the law, but also regulation and especially compliance practice. 

The focus for the 37th symposium was the shared responsibility borne by public and private bodies, across international borders, to fight economic crime. In particular, it looked at the flow of information between agencies and the business world, and how to tackle the issues that this presents. In addition to its keynote speeches and focal discussions each day, there were a host of alternative programmes, plenary sessions and workshops that enabled attendees to share their knowledge, garner new skills, and build new connections.

NEW YORK (August 15, 2019) — Kostelanetz & Fink is pleased to announce that The Best Lawyers in America has recognized six of its attorneys in its 2020 edition. The Best Lawyers in America (2020 edition), released August 15, 2019, recognizes the firm’s attorneys in the areas of Litigation and Controversy – Tax, Tax Law, Commercial Litigation, and Criminal Defense: White Collar. The annual list is based on a peer review process and reflects the consensus opinion of leading lawyers about the professional abilities of their peers within the same geographical regions and practice areas, according to the Best Lawyers website.  

The Institute is the premier tax controversy event in San Diego. The region's top tax attorneys, CPAs, and law/business school professors discussed topics including passthrough planning, Wayfair, ethical pitfalls to avoid in practice, and employee classification issues in California.

Caroline Ciraolo, partner with Kostelanetz & Fink, LLP in Washington, D.C. and former Acting Assistant Attorney General of the Tax Division, U.S. Department of Justice, discussed current priorities of the IRS and the Tax Division, domestic and international audit campaigns, current staffing and budget issues, new investigative units, and recent enforcement statistics.

The IRS has offered noncompliant taxpayers a path to come into compliance for decades. First, under the Internal Revenue Manual voluntary disclosure practice, and then under the historic Offshore Voluntary Disclosure Programs. In November 2018, the IRS announced new provisions that will apply to all future domestic and offshore voluntary disclosures. Since then, practitioners have been debating the new voluntary disclosure practice and its impact on clients, and taxpayers are wondering if this is the best approach to resolve outstanding issues. The panelists outlined the new framework and engaged in a spirited discussion regarding various open issues and best practices.

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Richard E. Zuckerman, Esq., Principal Deputy Assistant Attorney General, Tax Division, US Department of Justice, Washington, DC
Interviewer: Caroline D. Ciraolo, Esq., Partner, Kostelanetz & Fink, Washington, DC

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International tax enforcement is a top priority of the IRS and the Department of Justice. Audits and investigations routinely involve the collection of information, documents, and testimony outside the United States, leaving tax practitioners to determine what, if any, privilege applies and how those privileges can be preserved in various jurisdictions. This panel of experienced tax controversy attorneys addressed common privileges that arise in tax matters, the holder and scope of those privileges, the extent to which such privileges can be waived or set aside, and how to navigate these waters in foreign and cross-border audits and investigations.

U.S. taxpayers and residents are required under the Internal Revenue Code and the Bank Secrecy Act to report their relationship to foreign accounts and assets on an annual basis. The IRS and the Department of Justice have significantly increased enforcement of these reporting requirements through criminal prosecutions and the imposition of crushing civil penalties that can come when taxpayers are not compliant. This panel explored the current state of IRS and DOJ civil and criminal enforcement with respect to taxpayers who have not complied with FBAR (Report of Foreign Bank and Financial Accounts) and FATCA (Foreign Account Tax Compliance Act) reporting requirements. The panel also covered pathways to compliance for the non-compliant taxpayer, including the IRS’s Voluntary Disclosure Practice.