Caroline D. Ciraolo moderated a panel titled "Ethical Pitfalls and How to Avoid Them When Representing Clients in IRS Collections and Audits," at the University of San Diego School of Law - RJS LAW Tax Controversy Institute 2019
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 D. Ciraolo presented the CPE/CLE course "What’s New in Federal Tax Enforcement?" at The American Academy of Attorney-CPAs 2019 Annual Meeting & Education Conference
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.
Michael Sardar and Caroline Ciraolo participated in a panel titled "IRS Voluntary Disclosures: Past, Present, And Future" at The American Academy of Attorney-CPAs 2019 Annual Meeting & Education Conference
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.
Caroline D. Ciraolo moderated a panel titled "How Well Do Your Secrets Travel? Understanding the Scope of Privileges in Crossborder Audits and Investigations" at the NYU SCPS 11th Annual Tax Controversy Forum
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.
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
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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 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
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Caroline D. Ciraolo Participated in the Panel "Addressing Conflicts of Interest in Today's Tax Practice" at the Tax Alliance Conference in Dallas, TX on June 5, 2019
Caroline D. Ciraolo participated in the panel "Addressing Conflicts of Interest in Today's Tax Practice" at the Tax Alliance Conference in Dallas, TX on June 5, 2019.
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.