This list appeared in the December 2017 issue. The latest list will launch January 1, 2019.
Washington has a higher concentration of people with JDs than anywhere else in the country, which means you’re probably out of luck if you want to pick a fight with the homeowners’ association over landscaping rules—chances are the HOA president litigates much higher-stakes matters for a living. Also, you should really keep your voice down if you must tell that lawyer joke while riding Metro. Finally, it means this list is pretty tough to compile.
Caroline D. Ciraolo participated in the panel titled "Tax Preparer Investigations And Penalties" at the 2018 New England IRS Representation Conference
The penalty rules for tax return preparers pose significant challenges for tax practitioners and their clients. There often is a great amount of uncertainty about what a “tax shelter” is and when and how to disclose return positions. Practitioners must also wrestle with regard to conducting proper due diligence, understanding the standards of conduct necessary to avoid 6694 penalties and determining when to rely on information provided by clients or third parties.
Caroline D. Ciraolo moderated the panel titled "Addressing Conflicts Of Interest In Today's Tax Practice" at the 2018 New England IRS Representation Conference
Practitioners are often faced with ethical conundrums in everyday practice. The representation of spouses in an exam, discovering information not reported in a prior year, issues with financial information that surfaces after it has been provided to the IRS, etc. Our panel of practitioner and government experts reviewed these situations and discussed them so that attendees will know what to do (and not do) when these issues arise.
Caroline D. Ciraolo presented "Coming Attractions In Civil Tax Controversies And Criminal Tax Investigations" at the AICPA Sophisticated Tax Planning For Your Wealthy Clients Conference
Obtain clarity in changing times.
The monumental passing of the Tax Cuts and Jobs Act results in historic tax reform impacting nearly every American. This has brought about exciting opportunities for CPAs and financial planners. Your guidance will help your affluent clients achieve their financial goals and help you generate new business.
Caroline D. Ciraolo participated in the panel titled "Global Tax Enforcement: Compliance And Risk Mitigation (Part II)" at the Bahamas Financial Services Board
Governments across the world are conducting cross-border investigations and cooperating with each other to identify and prosecute tax evasion and other economic crimes that drain government coffers. The targets of these cross-border investigations include not only the taxpayers themselves, but also the domestic and foreign financial institutions and other entities and individuals who are believed to have facilitated the taxpayers’ conduct.
Caroline D. Ciraolo presented "The Long War Continues: Considerations In Litigating The FBAR Penalty" at the 2018 Annual Meeting of the California Tax Bar & California Tax Policy Conference
The IRS’ campaign against taxpayers with undisclosed offshore accounts and assets is entering its second decade. One of the principal weapons to enforce compliance is the civil FBAR penalty, which the IRS has been using with increasing frequency. This has resulted in a rising number of civil FBAR cases.