Caroline D. Ciraolo and Michael Sardar Participated In A Panel Titled "FBAR & FATCA: The Crackdown On Unreported Foreign Assets Continues" at The AICPA ENGAGE 2019 Conference
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.
CAROLINE D. CIRAOLO AND BRYAN C. SKARLATOS PARTICIPATED IN A PANEL ON "IRS CONTROVERSIES" AT THE AICPA ENGAGE 2019 CONFERENCE
As IRS enforcement becomes more automated, the need for trained representatives who know what to do and when to do it has never been greater. This panel covered the mechanics of representing taxpayers before the IRS, including exam and collections, so that attendees can identify and understand when taxpayers need help, and how to go about the process of helping them resolve their IRS issue.
1) Explain the process for challenging an exam issue with the IRS
2) Understand the IRS collection process
Click here for more information
Caroline D. Ciraolo and Bryan C. Skarlatos participated in a panel on "IRS Exams and Appeals" in the IRS Workshop at the AICPA ENGAGE 2019 Conference
As IRS enforcement becomes more automated, the need for trained representatives who know what to do and when to do it has never been greater. This panel covered the mechanics of representing taxpayers before the IRS, including Exam, Appeals and Collections, so that attendees could identify and understand when taxpayers need help, and how to go about the process of helping them resolve their IRS issue. This session was covered in 2 parts: 1:00 - 3:00 pm: Part 1 - Examinations and Appeals (Bryan Skarlatos and Caroline Ciraolo) 3:00 - 5:00 pm: Part 2 - IRS Collections (Eric Green, Robert McKenzie and Paul Mamo, IRS Director of Collections).
1. Understand the examination process
2. Identify opportunities to challenge an examiners findings
3. Explain the process for appealing from an IRS examination
4. Understand the IRS collection process
5. Explain the options taxpayers have to resolve an outstanding tax debt
Click here for more information
Caroline D. Ciraolo moderated the panel titled "The Current State Of The IRS, Personal Income Tax Committee" at the New York City Bar
For years Congress has asked the IRS to do more with less. Notwithstanding budget cuts, the Service remains responsible for, among other things, civil and criminal tax enforcement and assisting millions of taxpayers comply with their legal obligations. This Town Hall addressed how fiscal constraints affect the IRS’s ability to execute its mission. Caroline Ciraolo, the former Acting Assistant Attorney General of the Department of Justice's Tax Division, moderated a discussion of the Service’s current enforcement priorities as well as its efforts to assist taxpayers and taxpayer representatives facing bureaucratic hurdles and complex tax issues.
Caroline D. Ciraolo and Megan L. Brackney participated in the panel titled "Are Your Secrets Safe? A Discussion Of The Scope, Application And Protection Of Legal Privileges In The US And Abroad" at the ABA Section of Taxation, May Tax Meeting
Information is power and, in civil audits and criminal investigations, the government seeks to identify and obtain as much information as possible. To the extent such information falls within a recognized legal privilege, it is up to counsel for the taxpayer or target to timely and properly assert the applicable privilege and defend that privilege if the government seeks to compel production. This panel of experienced tax litigation and controversy attorneys addressed the 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 jurisdictions and cross-border investigations.
CAROLINE D. CIRAOLO PARTICIPATED IN THE PANEL TITLED "COLLECTION-BASED TAX CRIMES" AT THE ABA SECTION OF TAXATION, MAY TAX MEETING
Fraud referrals for collection-based tax crimes are on the rise as the IRS seeks to close the tax gap. This panel provided current statistics on, and review of, the tax crimes most likely to be encountered in collection, including willful failure to collect tax, fraud and false statements, and attempts to interfere with the administration of the internal revenue laws. The panelists also discussed practical approaches to handling civil collection cases with criminal implications and how to navigate a criminal collection case.