Part 2 of our interview with Caroline Ciraolo, partner with Kostelanetz & Fink and former Acting Assistant Attorney General of the US Department of Justice's Tax Division, we take a deeper dive into the types of tax professionals and government officials that may play a role in a client’s tax matters, the nature and risks of an “eggshell” audit, the scope of applicable privileges, best practices for vetting clients and managing an examination or investigation, and much more.  

Caroline’s 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. accoun tholders, 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 Vice President of the American College of Tax Counsel, Chair of the Civil and Criminal Tax Penalties Committee of the American Bar Association’s Section of Taxation, and 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).

Click here to read Caroline’s full bio

Charles Bruce is Legal Counsel of ACA, Chairman of ACA’s sister organization, ACA Global Foundation, former Tax Counsel of the Senate Finance Committee, Adjunct Professor of Law at Georgetown University Law Center, in Washington, and Visiting Professor, Institute of Foreign and International Finance and Taxation, Hamburg University. He divides his time between London and Washington DC.

Listen to Part 1 of our interview or here