Caroline D. Ciraolo moderated the panel titled "May I Have My Money Back Now Please? The Legal Landscape Overseas And Strategies To Navigate International Asset Seizures" at the 10th Annual NYU Tax Controversy Forum
Governments around the world are paying more attention to the source and use of money that passes through their financial systems and enacting legislation, such as the UK Criminal Finances Act of 2017, to combat the facilitation of tax evasion. Drawing on their experience in government and private practice, this panel reviewed the UK approach, including how financial institutions react to suspicious transactions, outlining the procedures for restraining and seizing accounts and offering strategies you can use to assist clients when a financial institution suspends access to an account.
Caroline D. Ciraolo participated in the panel titled "Department Of Justice Update" at the 10th Annual NYU Tax Controversy Forum
Voluntary compliance and enforcement of the tax law are at the heart of our tax system. Over the past several years, the IRS and DOJ have been challenged to come up with new and more efficient ways to ensure that all taxpayers pay the correct amount of tax. This panel provided an update on new developments and priorities across the IRS and DOJ.
Caroline D. Ciraolo participated in the panel titled "Answers Needed: Tax Research For Tax Problem Resolution Practitioners" at the 2018 IRS Tax Problem Resolution Spring Conference
Every Enrolled Agent, CPA, or attorney, on occasion, needs to research an important tax problem issue for their client. You may need to examine the required procedures for filing a lien or levy when you believe the IRS has violated proper procedure. When you encounter threats from a rogue Revenue Officer, you need to research her rights to do what she is threatening.
Caroline D. Ciraolo participated in the panel titled "Fundamentals Of Tax Litigation: Choice Of Forum And Appealing Decisions" at the ABA Section of Taxation 2018 May Meeting
This panel discussed some of the basics of tax litigation; choosing a forum for litigating a tax dispute; and procedures for appealing decisions from the different trial forums. Panelists discussed jurisdictional requirements and limitations of the various courts, differences in discovery practice, trial procedure, drafting litigation documents, and procedures for appealing.
Caroline D. Ciraolo participated in the panel titled "Collection Of Title 31 International Penalties" at the ABA Section of Taxation 2018 May Meeting
With the increase in international enforcement efforts and heightened focus on anti-money laundering and anti-tax evasion, individuals and entities are finding themselves subject to substantial civil penalties for failing to report foreign financial accounts and other violations of the Bank Secrecy Act. This panel reviewed the Title 31 civil penalties, the methods by which the United States can collect such penalties, available defenses, and best practices for pursuing collection alternatives.
Caroline D. Ciraolo participated in the panel titled "The Gathering Storm: Grappling With The Impact Of Restitution Orders On Civil Tax Litigation" at the ABA Section of Taxation 2018 May Meeting
In criminal cases involving tax counts, defendants being sentenced frequently wish to show remorse by paying the criminal tax loss prior to sentencing. These payments generally predate any actual civil tax determinations, let alone an IRS assessment. To allow the IRS to assess and collect an amount of restitution as if such amount were tax, Congress, in 2010, amended section 6201(a)(4). The result was that sentencing district court judges could now issue Restitution Orders permitting immediate assessment of the tax loss amount by IRS.