By Caroline D. Ciraolo
Journal of Tax Practice and Procedure
Spring 2020 Edition
At the 35th Annual UCLA Extension Tax Controversy Institute, Caroline D. Ciraolo and her fellow panelists addressed international tax compliance and enforcement, including what’s old, what’s new and what we can expect going forward.
“We cannot continue to operate in the same ways we have in the past, siloing our information from the rest of the world while organized criminals and tax cheats manipulate the system and exploit vulnerabilities for their personal gain. The J5 [Joint Chiefs of Global Tax Enforcement] aims to break down those walls, build upon individual best practices, and become an operational group that is forward-thinking and can pressurize the global criminal community in ways we could not achieve on our own.” Don Fort, Chief of IRS Criminal Investigation (July 2, 2018).
By Wendy Abkin, George Abney, and Caroline D. Ciraolo
Tax Executive Institute
TO DISCLOSE OR NOT TO DISCLOSE, THAT IS THE QUESTION
Hamlet’s thoughts weighed heavily upon him. Should he suffer the slings and arrows of outrageous fortune, or take arms against a sea of troubles? For the young Prince of Denmark seeking to avenge his father’s death, the choice was action or inaction, and ultimately life or death. Fortunately, most tax problems do not have such grave outcomes. Seemingly inconsequential tax errors can, however, lead to severe financial consequences. And, remote as it may seem, the prospect of imprisonment for tax crimes cannot be overlooked. When a past wrong is discovered, what should you do?