Caroline Ciraolo

Kostelanetz LLP

My Contact Information

Kostelanetz LLP

Washington, DC

Mobile: 443-845-4898

http://www.kflaw.com/

Caroline Ciraolo

Kostelanetz LLP

Bio

Caroline Ciraolo, former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division, is a partner with Kostelanetz & Fink, LLP and founder of its Washington, D.C. office. Her practice focuses on civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, and representing individuals and entities in criminal tax investigations and prosecutions.

During her tenure with the Justice Department, Caroline was actively involved in all aspects of Tax Division operations and responsible for approximately 500 employees, including more than 360 attorneys in 14 civil, criminal, and appellate sections. Under her leadership, the Division reached agreements with 80 Swiss financial institutions that admitted to facilitating tax evasion and the avoidance of reporting requirements by U.S. accountholders, and imposed and collected more than $1.36 billion in penalties, increased civil and criminal enforcement with respect to offshore tax evasion, employment tax violations, and traditional tax offenses, assisted the IRS through summons enforcement proceedings, and engaged in affirmative and defensive litigation involving abusive tax shelters and schemes, refund claims, and challenges to statues and regulations.

Caroline is a Fellow and Officer of the American College of Tax Counsel and Chair of the Civil and Criminal Tax Penalties Committee of the American Bar Association’s Section of Taxation. Caroline has also served as an instructor with the IRS Military Volunteer Income Tax Assistance program at Ft. George G. Meade in Maryland

She has been recognized by Chambers (Tax Fraud (Nationwide), Tax (DC)), Benchmark, Best Lawyers in America (Litigation and Controversy – Tax, Tax Law), Super Lawyers (Top 10 Attorneys in Maryland, Maryland cover story in 2013, DC), Euromoney Legal Media Group’s Americas Women in Business Law Awards (Best in Tax Dispute Resolution) (2014), and The Daily Record’s Top 100 Women Circle of Excellence. Caroline is a recipient of the ABA Section of Taxation’s Janet Spragens Pro Bono Award, and in January 2017, she was recognized by IRS Chief Counsel William Wilkins with the Chief Counsel Award, the highest honor that can be conferred by that office.

Caroline is an Adjunct Professor at the Georgetown University Law Center (International Tax Controversies, Tax Fraud and Tax Crimes) and University of Baltimore School of Law Graduate Tax Program (Investigation, Prosecution and Defense of Tax Crimes).

Experience

Partner, Kostelanetz & Fink, LLP (May 1, 2017 - present), Washington, D.C.
Tax Division, U.S. Department of Justice, Washington, DC

Acting Assistant Attorney General (February 2015 - July 2016)
Principal Deputy Assistant Attorney General (January 2015 - January 2017)
Deputy Assistant Attorney General for Policy and Planning (January 2015 -January 2017)
Deputy Assistant Attorney General for Criminal Matters (October 2015 - January 2017)

Partner, Rosenberg Martin Greenberg, LLP (November 2003 - January 2015), Baltimore, MD
Partner, Martin, Snyder & Bernstein, PA (December 2002 - November 2003), Baltimore, MD
Associate, Martin, Snyder & Bernstein, PA (formerly Martin, Junghans, Snyder & Bernstein, PA) (August 1996-December 2002), Baltimore, MD
Attorney Advisor, Honorable Stanley J. Goldberg, U.S. Tax Court (August 1994-August 1996), Washington, DC
Associate, Law Offices of James P. Koch, Baltimore, MD (August 1993-August 1994)

Education

University of Baltimore School of Law, LL.M. in Taxation (1994)
University of Maryland, School of Law, J.D. (Honors) (1993)
The College of New Jersey, B.S. in Finance (Honors) (cum laude) (1990)

Bar Admissions

Maryland (1993)
Pennsylvania (1995)
New Jersey (1995)
District of Columbia (1995)
US Tax Court
US District Court, District of Maryland
US Court of Federal Claims
US Court of Appeals, Fourth Circuit
US Court of Appeals, Ninth Circuit
US Court of Appeals, Federal Circuit
US Supreme Court

Faculty Positions

Adjunct Professor, Georgetown University Law Center (International Tax Controversies; Tax Fraud and Tax Crimes)
Adjunct Professor, University of Baltimore School of Law and Graduate Tax Program (Investigation, Prosecution and Defense of Tax Crimes)

Memberships & Affiliations

Fellow, American College of Tax Counsel

Vice President (2020-)
Secretary/Treasurer (2019-20)
Regent (4th Circuit) (2017-19)

Fellow, Litigation Counsel of America
Fellow, Maryland Bar Foundation
Trustee, Baltimore Bar Foundation
MD State Bar Association: Taxation Section

Council (2001-14)
Chair (2008-09)
Chair-Elect (2007-08)
Secretary/ Treasurer (2006-07)
Tax Controversy Group, Founder

Chair (2004-08)
Advisor (2009-14)

American Bar Association, Section of Taxation

Civil and Criminal Tax Penalties Committee

Chair, (2019-)
Vice-Chair (2009-14, 2017-19)
Sub-Committee Chair - Important Criminal Developments (2004-08)

Appointments to the Tax Court Committee (2019-)
Nominating Committee (2011-14, 2018-19)
Public Fellowship Committee (2009-13)
Pro Bono Award Committee (2012-14)

Member, Serjeant’s Inn
Member, Rule Day Club
Member, Barrister’s Club
Member, U.S. Tax Court Inn of Court
Member, Women’s White Collar Defense Association
Member, Network 2000

Co-chair, Women of Excellence Luncheon (2013-14)
Member, Board of Directors (2014)

Member, Board of Directors, Maryland Volunteer Lawyer Service (2009-14)

Chair, Annual Benefit (2012-14)

Member, Board of Directors, Federal Bar Association (Maryland Chapter) (2014)
Member, Day 4 Committee (State and Local Tax), Advanced Tax Institute, Maryland State Bar Association and Maryland Association of CPAs (2006-14)
Member, Advisory Board, Thomson West Tax (2007-14)
Member, Tax Advisory Board, Wolters Kluwer (2013-14)
Member, Advisory Board, CCH Journal of Tax Practice & Procedure (2011-14, 2017-)
Instructor, Military Volunteer Income Tax Assistance (VITA) Program, Fort George G. Meade, Fort Meade, Maryland (2012-15, 2018)
Member, Advisory Board, Choice Jobs Program (2010-15)
Member, Advisory Board, Fannie Angelos Program for Academic Excellence (2014)
Sponsor, U.S. Naval Academy Sponsor Program

Awards & Honors

Chambers USA, Nationwide: Tax Fraud, District of Columbia: Tax
Recognized as a Top Tax Lawyer by Washingtonian (2017-2019)
Recognized as a Women in Tax Leader by International Tax Review (2017-2020)
IRS Office of Chief Counsel Award (2017)
The Daily Record’s Leadership in Law (2015)
Best Lawyers in America - Litigation & Controversy – Tax (2011-14, 2019, 2020); Lawyer of the Year, Litigation & Controversy - Tax (2012) (Baltimore)
Nominee (shortlist), Euromoney Legal Media Group’s Americas Women in Business Law Awards (Best in Tax Dispute Resolution) (2014)
DC Super Lawyers (Tax) (2019, 2020)
Maryland Super Lawyers (Tax) (2009-15, 2020); Top 10 Attorneys in Maryland (2013-15); Top 25 Women Attorneys in Maryland (2009-11); Top 50 Women Attorneys in Maryland (2012-15); Top 100 Attorneys in Maryland (2010-15)
Featured on the cover of Maryland Super Lawyers Magazine (2013); and featured article (2018)
Featured in CNN Money Magazine – Money Hero (April 2013)
Benchmark: America's Leading Litigation Firms and Attorneys (2013-14)
Baltimore SmartCEO Magazine's Legal Elite (2009, 2010)
Martindale-Hubbell® Bar Register of Preeminent Women Lawyers™
Janet R. Spragens Pro Bono Award, ABA Section of Taxation (2010)
The Daily Record's Top 100 Women in Maryland (2010, 2012, 2014)
The Daily Record’s Circle of Excellence (Women in Maryland) (2014)
Maryland Volunteer Lawyers Service Educator Award (2008)
U.S. Tax Court Pro Bono Program, Maryland State Bar Association – Founder (2008/2009), Coordinator (2008-10), Volunteer (2008-14)

U.S. Tax Clinic Pro Bono Clinic – Co-Founder (2013), Volunteer (2013-14)

Judge, Public Service Fellowship, ABA Section of Taxation (2011-13)
Judge, Law Student Tax Challenge, ABA Section of Taxation (2011-14)
Judge, Janet R. Spragens Pro Bono Award, ABA Section of Taxation (2012-13)

Speaking Engagements (January 2017 – March 2020)

Participant, Forum on International Tax Disputes, Surrey, United Kingdom (February 26-28, 2020)
Speaker, Ethics, Data Breaches, and More, 44^th Annual Tax Law Conference, Federal Bar Association, Washington, DC (March 6, 2020)
Speaker, Criminal Tax Sentencing: Best Practices, 44^th Annual Tax Law Conference, Federal Bar Association, Washington, DC (March 6, 2020)

Co-Chair, Criminal Tax Symposium, 44^th Annual Tax Law Conference, Federal Bar Association, Washington, DC (March 5 and 6, 2020)
Speaker, Financial Crimes Enforcement, Compliance & Risk Mitigation, Bahamas Financial Services Board, Nassau, Bahamas (February 19, 2020)
Speaker, Women in Tax, Georgetown University Law Center, Washington, D.C. (February 12, 2020)
Moderator, Update: Tax Division, U.S. Department of Justice, Midyear Meeting, Section of Taxation, American Bar Association, Boca Raton, FL (February 1, 2020)
Interviewee, People in Tax, ABA Tax Times Podcast (January 3 and 9, 2020)
Panelist, The Consequences of Conviction – The Sentencing Guidelines, Restitution, Forfeiture and Other Bad Things That Happen, 36th Annual National Institute on Criminal Tax Fraud and 9th Annual National Institute on Tax Controversy, Las Vegas, NV (December 12, 2019)
Speaker, Criminal Tax Workshop, 36th Annual National Institute on Criminal Tax Fraud and 9th Annual National Institute on Tax Controversy, Las Vegas, NV (December 11, 2019)
Panelist, Tax Fraud Red Flags, Financial Crimes Enforcement Conference, American Bar Association/American Bankers Association, Washington, D.C. (December 9 and 10, 2019)
Panelist, Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules that Every Tax Advisor Should Know, Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2019, Practicing Law Institute, Los Angeles, CA (December 6, 2019)
Panelist, Application of Authority in the Changing World of Deference, 67th Annual Taxation Conference, University of Texas School of Law, Austin, TX (December 5, 2019)
Panelist, Balancing Tax Planning, Advocacy, and Professional Ethics: The Rules that Every Tax Advisor Should Know, Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2019, Practicing Law Institute, Los Angeles, CA (December 6, 2019)
Moderator, A Conversation with Nina Olson, former National Taxpayer Advocate, 2019 New England IRS Representation Conference, Uncasville, CT (November 22, 2019)
Panelist, Criminal Aspects of IRS Collection Cases, 2019 New England IRS Representation Conference, Uncasville, CT (November 22, 2019)

Panelist, What You Really Need to Know if You are Taking on a Criminal Tax Case, 2019 Criminal Tax Update, Pennsylvania Association of Criminal Defense Lawyers, Philadelphia, PA (November 21, 2019)
Speaker, Tax Controversies - IRS Practice Update, Sophisticated Tax Planning for Your Wealthy Clients, AICPA, Philadelphia, PA (November 18, 2019)

Panelist, From the Experts: Tax Controversy and Tax Litigation – Civil and Criminal Tax Update, 78^th Institute on Federal Taxation, New York University, San Francisco, CA (November 10, 2019)
Panelist, What Every Estate Planner Needs to Know About International Tax and Reporting, and the Government’s Enforcement and Initiatives, 2019 Annual Meeting of the California Tax Bar & California Tax Policy Conference, San Diego, CA (November 8, 2019)
Panelist, IRS Voluntary Disclosure Program and Updates on the Other Offshore Procedures, 56^th Annual Hawaii Tax Institute, Honolulu, Hawaii (November 5, 2019)
Panelist, Caution Trustees - Beware of Unresolved Tax Liabilities of Incapacitated Taxpayers and Decedents; Ethical Considerations, 56^th Annual Hawaii Tax Institute, Honolulu, Hawaii (November 4, 2019)
Panelist, Paying U.S. Taxes in Canada: Are You Caught on the Borderline?, Pathways to US Tax, Windsor, OH, Canada (November 2, 2019)
Speaker, Recruiting and Retaining Women in Tax - What Does it Take, Tax Section of the Federal Bar Association, Washington, D.C. (October 25, 2019)
Speaker, The New Age of Voluntary Disclosures, Graduate Tax Scholars, Georgetown University Law Center, Washington, D.C. (October 24, 2019)
Panelist, International Enforcement - What’s Old, What’s New and What We Can Expect, 35^th Annual UCLA Extension’s Tax Controversy Institute, Beverly Hills, CA (October 22, 2019)
Panelist, IRS International Tax Enforcement in a Post-OVDP World, 15^th Annual University of San Diego School of Law Procopio International Tax Institute, San Diego, CA (October 18, 2019)
Panelist, Identifying the Line Between Avoidance and Evasion: Global Criminal Tax Enforcement, 15^th Annual University of San Diego School of Law Procopio International Tax Institute, San Diego, CA (October 17, 2019)

Speaker, No Good Deed Goes Unpunished: Potential Liability of Executors and Beneficiaries for a Decedent’s Tax Liabilities, Serjeant’s Inn, Baltimore, MD (October 2, 2019)
Speaker, Preserving Confidentiality in Cross Border Investigations, 37th Annual Cambridge International Symposium on Economic Crime, Cambridge, England (September 3, 2019)
Panelist, Cooperation or Compulsion: The Emerging U.S. Experience With Voluntary and Involuntary Disclosures of Foreign Transactions, 37th Annual Cambridge International Symposium on Economic Crime, Cambridge, England (September 3, 2019)
Panelist, Ethical Pitfalls and How to Avoid Them When Representing Clients in IRS Collections and Audits, University of San Diego School of Law - RJS LAW Tax Controversy Institute 2019, San Diego, CA (July 19,2019)
Speaker, What’s New in Federal Tax Enforcement?, The American Academy of Attorney-CPAs 2019 Annual Meeting & Education Conference (July 5, 2019)
Panelist, IRS Voluntary Disclosures: Past, Present, and Future, The American Academy of Attorney-CPAs 2019 Annual Meeting & Education Conference, Orange Beach, AL (July 5, 2019)
Interviewer, Department of Justice Update with Principal Deputy Assistance Attorney General of Tax Division, Richard Zuckerman, NYU SCPS 11th Annual Tax Controversy Forum (June 21, 2019)
Moderator, How Well Do Your Secrets Travel? Understanding the Scope of Privileges in Cross border Audits and Investigations, NYU SCPS 11th Annual Tax Controversy Forum (June 20, 2019)
Panelist, FBAR & FATCA: The Crackdown on Unreported Foreign Assets Continues, AICPA ENGAGE 2019 Conference (June 11, 2019)

Panelist, IRS Controversies, AICPA ENGAGE 2019 Conference (June 11, 2019)
Panelist, IRS Examinations and Appeals, IRS Workshop, AICPA ENGAGE 2019 Conference (June 10, 2019)
Panelist, Addressing Conflicts of Interest in Today’s Tax Practice, Tax Alliance Conference, Dallas, TX (June 5, 2019)
Moderator, The Current State of the IRS, Personal Income Tax Committee, New York City Bar, New York, NY (May 28, 2019)
Moderator, Whistleblowers: Protections and Privacy, 4th International Conference on Taxpayer Rights, Minneapolis, MN (May 24, 2019)
Panelist, Are your secrets safe? A Discussion of the Scope, Application and Protection of Legal Privileges in the U.S. and Abroad, ABA Taxation Section, May Meeting, Washington, D.C. (May 11, 2019)
Panelist, Collection-Based Tax Crimes, May Meeting, Section of Taxation, American Bar Association, Washington, DC (May 10, 2019)

Panelist, Parallel Proceedings, 3d Annual Lightfoot White Collar Institute, Birmingham, AL (May 8, 2019)
Speaker, Business or Pleasure? Navigating the Internal Revenue Code When Your Boat is a Business,” Recreational Boating Committee of the Maritime Law Association of the United States, New York, NY (May 2, 2019)
Panelist, Tax Advice in the Age of the 24-Hour News Cycle, Webinar, ABA Taxation Section (April 24, 2019)
Speaker, What’s New in Tax Enforcement – Current Priorities of the IRS and DOJ Tax Division, The Wranglers Law Club, Baltimore, MD (April 18, 2019)
Co-Chair/Moderator, Identifying the Line Between Avoidance and Evasion: Global Criminal Tax Enforcement,19th Annual U.S. and Europe Tax Practice Trends Conference, ABA, Paris, France (April 5, 2019)

Panelist, What Every Estate Planner Needs to Know About International Tax and Reporting, and the Government’s Enforcement and Initiatives, 27^th Annual Estate and Gift Tax Conference, Tax Section, California Lawyer’s Association, San Francisco, CA (March 15, 2019)
Panelist, Updated Voluntary Disclosure Procedures: Is this the Correct Path for Your Noncompliant Client?, 43^rd Annual Tax Law Conference, Federal Bar Association, Washington, DC (March 8, 2019)
Moderator, New Developments in Criminal Tax Enforcement, 33nd Annual National Institute on White Collar Crime, American Bar Association, New Orleans, LA (March 6, 2019)
Speaker, What’s New in Tax Enforcement – Current Priorities of the IRS and DOJ Tax Division, The Rule Day Club, Baltimore, MD (February 12, 2019)
Speaker, Criminal Tax Enforcement: What Lies Ahead in 2019, Georgetown Scholars Lunch, Georgetown University Law Center, Washington, DC (February 7, 2019)
Speaker, Current Developments – Tax Division, U.S. Department of Justice, 2019 ABA Taxation Section Midyear Meeting, New Orleans, LA (January 18, 2019)
Panelist, Tax Advice in the Age of the 24-Hour News Cycle, 2019 ABA Taxation Section Midyear Meeting, New Orleans, LA (January 18, 2019)
Keynote Speaker, Update from Washington, D.C., 37th Annual International Tax Conference, Tax Section, Florida Bar Association, Miami, Florida (January 10, 2019)
Moderator, Criminal Tax Workshop, 35th Annual National Institute on Criminal Tax Fraud and 8th Annual National Institute on Tax Controversy, Las Vegas, NV (December 13, 2018)
Speaker, Tax Preparer Investigations and Penalties, 2018 New England IRS Representation Conference, Uncasville, CT (November 30, 2018)
Speaker, Coming Attractions in Civil Tax Controversies and Criminal Tax Investigations, Sophisticated Tax Planning for Your Wealthy Clients, AICPA, Washington, DC (November 29, 2018)
Speaker, Global Tax Enforcement: Compliance and Risk Mitigation (Part II), Bahamas Financial Services Board, Nassau, Bahamas (November 21, 2018)
Speaker, IRS Employment Tax Update, 2018 Annual Meeting of the California Tax Bar & California Tax Policy Conference, San Jose, CA (November 9, 2018)
Speaker, The Long War Continues: Considerations In Litigating The FBAR Penalty, 2018 Annual Meeting of the California Tax Bar & California Tax Policy Conference, San Jose, CA (November 8, 2018)
Speaker, It’s A Small World - The Use of Exchange of Information for Tax Enforcement, 55^thAnnual Hawaii Tax Institute, Honolulu, Hawaii (November 6, 2018)
Speaker, Summer Of Norman, Wahdan, Colliot: Defending Title 31 FBAR Penalties: Pre And Post-Assessment, IRS & DOJ Policies And Strategy, 14^th Annual University of San Diego School of Law Procopio International Tax Institute, San Diego, CA (November 1, 2018)
Speaker, The New Wave Of Fraud Referrals – Fact Or Fiction, 34^thAnnual UCLA Extension’s Tax Controversy Institute, Beverly Hills, CA (October 23, 2018)
Moderator and Speaker, OVDP – End of an Era, May Meeting, Section of Taxation, American Bar Association, Atlanta, GA (October 6, 2018)
Panelist, It’s Good to Know the Bad: Financial Crime and How to Counsel Clients, Annual Meeting, Business Law Section, American Bar Association, Austin, TX (September 14, 2018)
Speaker, Keynote Address; Hot, Questionable, and Secret Money," 36th International Symposium on Economic Crime, Cambridge, England (September 4, 2018)
Speaker, Unexplained Wealth in the US: The USA Flexes its Muscle," 36th International Symposium on Economic Crime, Cambridge, England (September 4, 2018)
Plenary Keynote Speaker, Tax: The Good, the Bad, and the Ugly, Accounting & Finance Show New York, Terrapin, New York, NY (July 12, 2018)
Presenter, Identifying and Addressing Conflicts of Interest and Ethical Issues in Today’s Tax Practices, 42nd Annual Institute, American Institute on Federal Taxation, Hoover, AL (June 29, 2018)
Panelist, Department of Justice Update, 10^thAnnual Tax Controversy Forum, New York University, New York, NY (June 22, 2018)
Moderator, May I Have My Money Back Now Please? The Legal Landscape Overseas And Strategies To Navigate International Asset Seizures, 10^th Annual Tax Controversy Forum, New York University, New York, NY (June 22, 2018)
Panelist, Answers Needed: Tax Research for Tax Problem Resolution Practitioners, Spring Conference, American Society of Tax Problem Solvers, Atlanta, GA (June 8, 2018)
Panelist, The Criminal Prosecution: Prosecution & Defense Strategies, the Plea, and Sentencing, Quinnipiac University 2nd Annual Criminal Tax Day, North Haven, CT (May 17, 2018)
Panelist, What's New In Criminal Tax?, Quinnipiac University 2nd Annual Criminal Tax Day, North Haven, CT (May 17, 2018)
Panelist, Fundamentals of Tax Litigation: Choice of Forum and Appealing Decisions, May Meeting, Section of Taxation, American Bar Association, Washington D.C. (May 12, 2018)
Panelist, The Gathering Storm: Grappling with the Impact of Restitution Orders on Civil Tax Litigation, May Meeting, Section of Taxation, American Bar Association, Washington, D.C. (May 11, 2018)
Panelist, Collection of Title 31 International Penalties, May Meeting, Section of Taxation, American Bar Association, Washington, D.C. (May 11, 2018)
Panelist, Ethical Considerations for Government and Private Sector Tax Lawyers, Government and Public Sector Lawyers Division and Taxation Section, American Bar Association, Webinar (April 26, 2018)
Panelist, Fundamentals of Tax Litigation: Choice of Forum and Appealing Decisions, Young Lawyers Tax Symposium, Section of Taxation, American Bar Association and Federal Bar Association, Washington D.C. (April 13, 2018)
Presenter, Impact of Global Tax Enforcement, Graduate Tax Scholars, Georgetown University Law Center, Washington, D.C. (March 29, 2018)
Panelist, Exchange of Tax Information Around the World, 68^th Midyear Conference, Tax Executive Institute, Washington, D.C. (March 28, 2018)
Moderator, Tools Of The Trade - A Review Of The Government's Arsenal In Criminal Tax Investigations, 2018 FBA Tax Law Conference, Washington, D.C. (March 9, 2018)
Panelist, Balancing Privileges And Burdens Of Proof In Civil Trials Involving International Taxpayers, Crypto-Currency And Marijuana Businesses, 2018 FBA Tax Law Conference, Washington, D.C. (March 9, 2018)
Presenter, Taking On A Criminal Tax Case? Don’t Leave Home Without These Critical Practice Tips, 32nd Annual National Institute on White Collar Crime, San Diego, CA (February 28, 2018)
Presenter, The Impact Of Global Tax Enforcement, 2018 E.L. Wiegand Lecture, San Francisco, CA (February 16, 2018)
Presenter, The New Wave Of Fraud Referrals – IRS Collections, 2018 ABA Taxation Section Midyear Meeting, San Diego, CA (February 10, 2018)
Presenter, Evolving Constraints On Tax Administration At The IRS, 2018 ABA Taxation Section Midyear Meeting, San Diego, CA (February 9, 2018)
Panelist, Is There A Tipping Point?, Women's Leadership Forum, London, England (January 23, 2018)
Volunteer, IRS Military Volunteer Income Tax Assistance Adopt-A-Base Program, Fort Meade, MD (January 8, 2018)
Speaker, Penalties Above 20%: What Are They, When Are They Applied, And How Do You Defend?, 65th Annual Taxation Conference, University of Texas School of Law, Austin, TX (December 13, 2017)
Moderator, Criminal Tax Workshop, 34th Annual National Institute on Criminal Tax Fraud and 7th Annual National Institute on Tax Controversy, Las Vegas, NV (December 6, 2017)
Speaker, AML And Tax – What Every AML Officer Should Know About The New And Emerging Tax Issues, 2017 American Bankers Association and the American Bar Association Financial Crimes Enforcement Conference, National Harbor, MD (December 4, 2017)
Panelist, Cross Border Individual Matters, 30th Annual Institute on Current Issues in International Taxation, Georgetown Law School, Washington, D.C. (December 1, 2017)
Presenter, Global Tax Enforcement: Compliance & Risk Mitigation, Bahamas Financial Services Board, Nassau, Bahamas (November 29, 2017)
Speaker, Waking Up The Dead: Reopening Those Tax Assessments You Thought Were Final, 2017 New England IRS Representation Conference, Mashantucket, CT (November 17, 2017)
Speaker, The IRS And DOJ Continue To Prioritize Employment Tax Enforcement - Are You And Your Clients Prepared?, 2017 Annual Meeting of the California Tax Bar & California Tax Policy Conference, Carlsbad, CA (November 2, 2017)
Moderator, Continuing Enforcement And Disclosure Issues Regarding Foreign Assets, 5th Annual ABA International Tax Enforcement And Controversy Conference, Washington, D.C. (October 27, 2017)
Speaker, Voluntary Disclosures - Righting Past Wrongs, Tax Executives Institute 72nd Annual Conference, Toronto, Canada (October 25, 2017)
Speaker, From The Experts: IRS Representation Tools, Techniques, And Defensive Strategies – Civil & Criminal Tax Update, 76^th Institute on Federal Taxation, New York University, New York, New York (October 22, 2017) - download brochure
Speaker, Trends In Tax Transparency And Enforcement, Association of Certified Financial Crime Specialists (ACFCS) 2017 Financial Crime Conference, Boston, MA (October 17, 2017)
Speaker, Developments In International Tax Enforcement, D.C. Bar Tax Audits and Litigation Committee, Washington, D.C. (October 11, 2017)
Speaker, Tax Defense, 13th Annual East Coast White Collar Crime Conference, Washington, D.C. (September 14, 2017)
Speaker, U.S. International Tax Enforcement And Compliance, 35th International Symposium on Economic Crime, Cambridge, England (September 5, 2017)
Speaker, Keynote Address, 35th International Symposium on Economic Crime, Cambridge, England (September 4, 2017)
Speaker, Examination Do's and Don’ts, National Association of Tax Professionals, Washington, D.C. (August 10, 2017)
Speaker, Conflicts of Interest, National Association of Tax Professionals, Washington, D.C. (August 9, 2017)
Speaker, IRS Office of Chief Counsel Lecture Series, Washington, D.C. (June 29, 2017)
Panelist, A Perspective on IRS Virtual Currency Enforcement Action, Blockchain, Accounting, Audit & Tax Conference, Microsoft Technology Center, New York, NY (June 22, 2017)
Panelist, Tax Compliance and Enforcement Update – Department of Justice, NYU 9th Annual Tax Controversy Forum, New York, NY (June 16, 2017)
Panelist, International Exchange of Information and Evidence Gathering, NYU 9th Annual Tax Controversy Forum, New York, NY (June 15, 2017)
Panelist, Tax Enforcement Update: Significant Issues, Texas Federal Tax Institute, San Antonio, TX (June 14, 2017)
Speaker, Coming Attractions in Tax Controversies, 2017 Spring Conference, American Society of Tax Problem Solvers, San Antonio, TX (June 10, 2017)
Panelist, IRS Employment Tax Audits – Part II, May Meeting, ABA Section of Taxation, Washington, DC (May 12, 2017)
Luncheon Speaker, Audits & Appeals Seminar (Insights and Skills for Federal Tax Controversy Success), Tax Executives Institute, Chicago, IL (May 8, 2017)
Panelist, Offshore Tax Compliance Issues (from a Tax Controversy Perspective), Advanced Tax Procedure Seminar, Tax Section of the Florida Bar, West Palm Beach, FL (May 5, 2017)
Panelist, So This Is Privileged… Right?, Advanced Tax Procedure Seminar, Tax Section of the Florida Bar, West Palm Beach, FL (May 5, 2017)
Panelist, Recent Trends In Information-Gathering And Enforcement By The IRS, ICE, FinCEN, and DOJ, 17^th Annual Anti-Money Laundering Compliance Conference, Florida International Bankers Association (FIBA), Miami, FL (March 8, 2017)
Panelist, The Art of Storytelling as told by Women Leaders in Government, 31^st Annual National Institute on White Collar Crime, Miami, FL (March 9, 2017)
Speaker, Keynote Address, USC Gould School of Law 2017 Tax Institute, Los Angeles, CA (January 24, 2017

** Various Speaking Engagements as Acting Assistant Attorney General, Tax Division, U.S. Department of Justice (January 2015 – January 2017)

Publications and Speaking Engagements Prior to January 2015

Publications

Circular 230–Final Regulations and a New Principles-Based Approach, CCH's Journal of Tax Practice & Procedure (JTP&P) (August-September, 2014)
The Ins and Outs of Federal Criminal Tax Cases, Maryland Bar Bulletin (April, 2014)
The Tax Man is Coming Bank: A Word of Warning to Liquor Retailers, The Barrister (December 2013/January 2014)
The United States Strikes Again – The New Swiss Bank Program, Financier Worldwide (October, 2013)
The Reasonable Cause Defense to Penalties and Some Good News for Taxpayers, CCH's Journal of Tax Practice & Procedure (JTP&P) (August-September, 2013)
The FBAR Penalty: What Constitutes Willfulness?, Maryland Bar Journal (Taxation Issue, May-June, 2013)
The Eggshell Audit Part II: Indicators of Fraud and IRS Fraud Development Procedures, with Larry Campagna and Eric Green, JTP&P (February-March, 2013)
But I Relied on My Accountant! The Scope of the Reasonable Cause Defense to Penalties, co-authored with Larry Campagna and Ellis Reemer, JTP&P (August-September, 2012)
The Eggshell Audit Part I: A Primer, with Larry Campagna and Eric Green, JTP&P (June-July, 2012)
Criminal Tax Cases: A Primer, a chapter in Inside the Minds: Strategies for Criminal Tax Cases, Aspatore (2011)
Last Known Address, a chapter in the recently published, Effectively Representing your Client before the Internal Revenue Service, 5th Edition (ABA Section of Taxation (2011))
Frequently Charged Tax Crimes, Federal Public Defender National Conference, June, 2011
Refund Claims and Claims for Contribution, ABA Section of Taxation (May, 2011)
Editor, A Practitioner's Guide to Innocent Spouse Relief: Proven Strategies for Winning Section 6015 Tax Cases, by Robert B. Nadler (ABA Section of Taxation (2011))
FinCEN Issues Final FBAR Regulations, CCH JTP&P (April-May, 2011)
The Morning After – What You Need to Know FBAR and International Information Returns Including Defending Against and Litigating the Penalties, JTP&P (October-November, 2009)
Attaching Property Held as Tenancy by the Entirety: The Response to Craft, JTP&P (January 1, 2004)
Ask the Professionals (Various Tax-Related Topics), Baltimore Business Journal (2010 – present)

Speaking Engagements

Institute Co-Chair, 31st Annual National Institute on Criminal Tax Fraud and 4th Annual National Institute on Tax Controversy, Las Vegas, NV (December 10-12, 2014)
Panelist, Comprehensive Tax Enforcement, 31st Annual National Institute on Criminal Tax Fraud and 4th Annual National Institute on Tax Controversy, Las Vegas, NV (December 11, 2014)
Moderator, Criminal Tax Workshop, 31st Annual National Institute on Criminal Tax Fraud and 4th Annual National Institute on Tax Controversy, Las Vegas, NV (December 10, 2014)
Panelist,Criminal Tax Investigations: What To Do When Either You or Your Client is Contacted by an IRS Special Agent, New England IRS Representation Conference, Ledyard, CT (November 21, 2014)
Panelist,Eggshell Audits: Handling Civil Exams When There are Indications of Fraud, New England IRS Representation Conference, Ledyard, CT (November 21, 2014)
Panelist,Circular 230 & Reverse Circular 230: Ethical Issues for Practitioners Dealing with the IRS, and Ethical Issues for IRS Personnel When Dealing with Taxpayers and Practitioners, New England IRS Representation Conference, Ledyard, CT (November 21, 2014)
Panelist, Hot Topics in Tax Enforcement, 25^thAnnual Philadelphia Tax Conference, Philadelphia, PA (November 6, 2014)
Panelist, Litigation Forums and Key Procedures, Bloomberg BNA, Resolving IRS Tax Controversies, New York, New York (October 28, 2014)
Panelist, Eggshell Audits: Handling Federal Tax Audits when there are Potential Badges of Fraud, Bloomberg BNA, Resolving IRS Tax Controversies, New York, New York (October 27, 2014)
Conference Co-Chair, ALI CLE - Handling a Tax Controversy: Audit, Appeals, Litigation and Collections, Washington, D.C. (October 16-17, 2014)
Panelist, Ethics, ALI CLE - Handling a Tax Controversy: Audit, Appeals, Litigation and Collections, Washington, D.C. (October 17, 2014)
Panelist, Relief from Joint and Several Liability,ALI CLE - Handling a Tax Controversy: Audit, Appeals, Litigation and Collections, Washington, D.C. (October 16, 2014)

Panelist,Tax Controversy Clinic, Maryland Volunteer Lawyers Service, Baltimore, MD (October 2, 2014)
Moderator, Statutes of Limitations in International Civil and Criminal Tax Matters – The Rules and the Many Exceptions, Fall Meeting, ABA Section of Taxation, Denver, CO (September 20, 2014)

Panelist, ABCs of FBARs, Western Union, Webinar (July 28, 2014)
Speaker, Immigration and Taxation, IRS Nationwide Tax Forum, New Orleans, LA (July 24, 2014)
Panelist, Global Tax Enforcement Conference, Villa Marina, Douglas, Isle of Man (July 3, 2014)
Panelist, International Tax Enforcement Update, Teaneck, NJ (June 27, 2014)
Moderator, Good Practitioner/Bad Practitioner – Ethical Standards and Issues in Federal Tax Practice, NYU 6th Annual Tax Controversy Forum, New York, NY (June 20, 2014)

Speaker, Foreign Tax Issues, Maryland Society of Accounting & Tax Professionals, Gaithersburg, MD (June 12, 2014)

Panelist, Eggshell Audits: Handling IRS Examinations of Closely Held Businesses When There are Criminal Tax Issues, May Meeting, ABA Section of Taxation, Washington, DC (May 9, 2014)

Panelist, The Top 10 Tax Issues for 2014, May Meeting, ABA Section of Taxation, Washington, DC (May 8, 2014)

Panelist, Criminal Tax Update, Association of Federal Defense Attorneys (AFDA), Webinar (April 25, 2014)

Panelist, Symposium: U.S. Taxpayers’ Foreign Accounts: FATCA, Voluntary Disclosure & Summonses Documents, Graduate Tax Program, University of Baltimore School of Law and Taxation Section, Maryland State Bar Association (March 24, 2014)

Moderator, Coming into Compliance, 2d Annual International Tax Enforcement Conference, ABA Section of Taxation and Tax Executives Institute, Washington, D.C. (March 18, 2014)
Panelist, Ethical Issues Arising from Conflicts of Interest in Litigation, Midyear Meeting, ABA Section of Taxation, Phoenix, AZ (January 24, 2014)
Panelist, Business Development for Young Lawyers, Midyear Meeting, ABA Section of Taxation, Phoenix, AZ (January 24, 2014)
Conference Co-Chair, ALI CLE - Hot Topics for Accountants & Tax Lawyers: Tax Returns, Advice, & Examination, Philadelphia, PA (December 16, 2013)
Institute Co-Chair, 30th Annual National Institute on Criminal Tax Fraud and 3rd Annual National Institute on Tax Controversy, Las Vegas, NV (December 11-13, 2013)
Moderator, Criminal Tax Workshop: The Basics, 30th Annual National Institute on Criminal Tax Fraud and 3rd Annual National Institute on Tax Controversy, Las Vegas, NV (December 11, 2013)
Panelist, Commonly Charged Tax Crimes and Emerging Trends, University of Texas School of Law 61^st Annual Taxation Conference, Austin, TX (December 5, 2013)
Panelist, Money & Time: Sentencing Trends in Criminal Tax Cases, 2013 White Collar Practice Seminar, Pennsylvania Association of Criminal Defense Lawyers, Philadelphia, PA (November 14, 2013)
Panelist, Penalty Relief - Defensive Strategies and Practical Considerations, American Institute of Certified Public Accountants (AICPA), 2013 Tax Controversy Workshop, Washington, D.C. (November 6, 2013)
Panelist, Tax Controversy Clinic, Maryland Volunteer Lawyers Service, Baltimore, MD (November 5, 2013)
Conference Co-Chair, ALI CLE - Handling a Tax Controversy: Audit, Appeals, Litigation and Collections, Washington, D.C. (October 17-18, 2013)
Panelist, Relief from Joint and Several Liability, ALI CLE - Handling a Tax Controversy: Audit, Appeals, Litigation and Collections, Washington, D.C. (October 17, 2013)
Panelist, Administrative Collections, ALI CLE - Handling a Tax Controversy: Audit, Appeals, Litigation and Collections, Washington, D.C. (October 17, 2013)
Panelist, Closing Documents, Extensions and Qualified Offers, ALI CLE - Handling a Tax Controversy: Audit, Appeals, Litigation and Collections, Washington, D.C. (October 17, 2013)
Presenter, Assessment and Collection of the FBAR Penalty, Mannes Greenberg Wednesday Tax Study Group, Baltimore, MD (October 2, 2013)
Panelist, Criminal Tax Sentencing: Fairness and Deterrence, Villanova Law Review Norman J. Shachoy Symposium, Villanova, PA (September 27, 2013)
Panelist, Ethical Issues Arising from Conflicts of Interest, Fall Meeting, Taxation Section, American Bar Association, San Francisco, CA (September 20, 2013)
Presenter, Reporting Foreign Assets, Foreign Financial Accounts, and Cash Transactions- IRS 2013 National Tax Forum, Washington, D.C. (August 27, 2013)
Moderator, But It’s Not My Fault! The Scope of the Reasonable Cause Defense and Good Faith Exception to Tax Penalties, NYU 5th Annual Tax Controversy Forum, New York, NY (June 7, 2013)
Moderator, The Ethical Minefield: Practical Advice for Difficult Tax Practice Issues, Small Business Practitioners Tax Conference, American Institute of Certified Public Accountants (AICPA), Las Vegas, NV (May 17, 2013)
Panelist, Preparing and Arguing Your Case in IRS Appeals, Small Business Practitioners Tax Conference, American Institute of Certified Public Accountants (AICPA), Las Vegas, NV (May 17, 2013)
Panelist, How and When to Work with the Taxpayer Advocate, Small Business Practitioners Tax Conference, American Institute of Certified Public Accountants (AICPA), Las Vegas, NV (May 15, 2013)
Moderator, Restitution and Civil Tax Issues in Sentencing, ABA Section of Taxation, Webinar (May 14, 2013)
Moderator, Assisting Clients with the Bureau of Prisons: The Importance of Sentencing and Post-Sentencing Advocacy, May Meeting, ABA Section of Taxation, Washington, DC (May 11, 2013)
Moderator, An Ethics Challenge: Identifying and Addressing Conflicts of Interest in Tax Controversies, ABA Section of Taxation, Webinar (April 24, 2013)
Panelist, Through the Looking Glass (Part III): Opting Out of the OVDI Penalty Structure and Litigating FBAR Penalties, ABA Section of Taxation, Webinar (April 10, 2013)
Panelist, Careers in Tax Law, University of Baltimore, School of Law, Graduate Tax Program, Baltimore, MD (March 13, 2013)
Panelist, Through the Looking Glass (Part III): Opting Out of the OVDI Penalty Structure and Litigating FBAR Penalties, Midyear Meeting, ABA Section of Taxation, Orlando, FL (January 25, 2013)
Moderator, An Ethics Challenge: Identifying and Addressing Conflicts of Interest in Tax Controversies, Midyear Meeting, ABA Section of Taxation, Orlando, FL (January 25, 2013)
Panelist, Through the Looking Glass (Parts I and II): Opting Out of the OVDI Penalty Structure and Litigating FBAR Penalties, ABA Section of Taxation, Webinar (January 16, 2013)
Instructor, Volunteer Income Tax Assistance (VITA) Military Training Program, Ft. Meade Army Base, Ft. Meade, MD (2012-present)
Moderator, Restitution and Civil Tax Issues in Sentencing, ABA 29th Annual National Institute on Criminal Tax Fraud and 2d Annual National Institute on Tax Controversy, Las Vegas, NV (December 6, 2012)
Moderator, Criminal Tax Workshop: The Basics, ABA 29th Annual National Institute on Criminal Tax Fraud and 2d Annual National Institute on Tax Controversy, Las Vegas, NV (December 5, 2012)
Presenter, Tax Controversies in Divorce – Issues for Every Client, 17th Annual Symposium on Family Law, American Academy of Matrimonial Lawyers, Maryland Chapter, Ellicott City, MD (November 12, 2012)
Panelist, Civil Penalties on the International Front: Increasing Complexity and Peril for the Taxpayer, International Tax Enforcement Conference, ABA Section of Taxation and Tax Executives Institute, New York, NY (November 9, 2012)
Panelist, Voluntary Disclosures – Maryland and Beyond…, Advanced Tax Institute, Baltimore, MD (November 8, 2012)
Presenter, An Offshore Update – Review of the 2012 OVDP, FBAR Requirements and FATCA, Tax Controversy Study Group, Maryland State Bar Association, Baltimore, MD (October 17, 2012)
Presenter, IRS Examination Process, Virginia Society of Certified Public Accountants, Northern Chapter, Falls Church, VA (September 25, 2012)
Panelist, Through the Looking Glass (Part I): Opting Out of the OVDI Penalty Structure—What Happens Now?, Fall Meeting, ABA Section of Taxation, Boston, MA (September 14, 2012)
Panelist, Evidentiary Issues in Tax Litigation, Fall Meeting, ABA Section of Taxation, Boston, MA (September 14, 2012)
Panelist, Down the Rabbit Hole: The ABCs of Disclosure, ABA Section of Taxation, Fall Meeting, ABA Section of Taxation, Boston, MA (September 14, 2012)
Presenter, Reporting Foreign Assets, Foreign Financial Accounts, and Cash Transactions- IRS 2012 National Tax Forum, New York, NY (August 30, 2012)
Presenter, Examination Representation – 101, IRS 2012 National Tax Forum, New York, NY (August 28, 2012)
Panelist, But I Relied on My Accountant! – The Scope of Reasonable Cause Defense to Penalties, NYU 4th Annual Tax Controversy Forum, New York, NY (June 15, 2012)
Panelist, Understanding IRS Criminal Investigations, American Association of Attorneys-CPAs (AAA-CPAs), Capital Chapter, Baltimore, MD (June 5, 2012)
Panelist, Tax Workshop, RSM McGladrey, Baltimore, MD (May 31, 2012)
Moderator, Restitution and Civil Tax Issues in Sentencing, May Meeting, ABA Section of Taxation, Washington, DC (May 12, 2012)
Panelist, Eggshell Audits: Handling IRS Examinations of Closely Held Businesses When There are Criminal Tax Issues, May Meeting, ABA Section of Taxation, Washington, DC (May 11, 2012)
Panelist, What You Must Know About Tax Law Practice (That Your Law School – or LLM Program – May Not Have Taught You), May Meeting, ABA Section of Taxation, Washington, DC (May 10, 2012)
Panelist, The Ethical Minefield: Practical Advice for Difficult Tax Practice Issues, Small Business Practitioners Tax Conference, American Institute of Certified Public Accountants (AICPA), Las Vegas, NV (May 4, 2012)
Panelist, Preparing and Arguing Your Case in IRS Appeals, Small Business Practitioners Tax Conference, American Institute of Certified Public Accountants (AICPA), Las Vegas, NV (May 3, 2012)
Presenter, Defending Tax Cases, White Collar Practice Seminar, Office of the Federal Public Defender and the Federal Bar Association, District of Delaware, Wilmington, DE (April 20, 2012)
Panelist, Tax Controversy Training for Pro Bono Lawyers, Maryland Volunteer Lawyers Service (MVLS), Baltimore, MD (March 22, 2012)
Panelist, Tax Fraud, Foreign Banks and Bankers, "Required Records Doctrine" and Forfeitures, 26th Annual Institute on White Collar Crime, Miami, FL (March 1, 2012)
Panelist, Sentencing: How to Make the Best of a Bad Situation, Midyear Meeting, ABA Section of Taxation, San Diego, CA (February 18, 2012)
Speaker, IRS Criminal Tax Roundtable, 28th Annual National Institute on Criminal Tax Fraud and 1st Annual National Institute on Tax Controversy, Las Vegas, NV (December 1, 2011)
Panelist, Administrative Collection Procedures: Collection Due Process; Offers in Compromise and Installment Agreements; and Section 6672 Penalty Matters, How To Handle a Tax Controversy at the IRS & in Court: From Administrative Audit Through Litigation, American Law Institute and American Bar Association (ALI-ABA), Washington, DC (September 15, 2011)
Panelist, Tax Practice Ethics for Preparers and Advisors: How To Handle a Tax Controversy at the IRS & in Court: From Administrative Audit Through Litigation, American Law Institute and American Bar Association (ALI-ABA), Washington, DC (September 15, 2011)
Speaker, Recent Developments in Foreign Bank and Financial Account Reporting, ABA Section of Taxation, Webinar (June 14, 2011)
Panelist, The Truth About IRS Collection Alternatives: What Works and What Doesn't, NYU 3d Annual Tax Controversy Forum, New York, NY (June 10, 2011)
Presenter, Tax Crimes, National Seminar for Federal Defenders, Baltimore, MD (June 3, 2011)
Panelist, Trust Fund Recovery Penalties – From Investigation to Litigation, May Meeting, ABA Section of Taxation, Washington, DC (May 7, 2011)
Presenter, Civil Tax Controversies, Anne Arundel County Bar Association, Annapolis, MD (March 22, 2011)
Presenter, Voluntary Disclosures, Mannes Greenberg Wednesday Tax Study Group, Baltimore, MD (January 5, 2011)
Panelist, Employment Tax Examinations, Maryland Association of Certified Public Accountants, Southern Maryland Chapter, La Plata, MD (December 9, 2010)
Panelist, IRS Criminal Tax Roundtable, 27th Annual Criminal Tax Fraud Institute, San Francisco, CA(December 2, 2010)
Panelist, Civil Tax Penalty Abatements-Fact or Fiction?, ABA Section of Taxation, Webinar (November 3, 2010)
Panelist, The Nuts and Bolts of Handling a Pro Bono Tax Controversy - Part II, ABA Section of Taxation, Webinar (November 2, 2010)
Panelist, IRS Voluntary Disclosure Practice, MSBA Taxation Section, Webinar (October 27, 2010)
Panelist, The Nuts and Bolts of Handling a Pro Bono Tax Controversy - Part I, ABA Section of Taxation, Webinar (October 26, 2010)
Panelist, Civil Tax Penalty Abatements-Fact or Fiction?, Fall Meeting, ABA Section of Taxation, Toronto (September 25, 2010)
Presenter, Low Income Taxpayer Training, Maryland Volunteer Lawyers Service, Baltimore, MD (September 8, 2010)
Panelist, Defense and Litigation of Penalties associated with Foreign Bank Account Reports and International Information Returns, Fall Meeting, ABA Section of Taxation, Chicago, IL (September 26, 2009)

Practice Areas

Appeals
Corporate Crime
Government Investigations
Internal Investigations
Tax Controversy
Trials
White Collar Crime