The IRS and DOJ have been aggressive in pursuing judicial recourse to enforce and seek collection of FBAR assessments. STEP USA’s webinar addresses the key issues and considerations in the litigation of an FBAR case. The format for the presentation was an interactive question and answer format among the knowledgeable panelists. There was an opportunity for attendees to pose questions to the panelists.

Caroline Ciraolo, Partner, Kostelanetz & Fink, LLP, Washington, DC and Baltimore, MD.  Ms. Ciraolo is former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division.  She represents individuals and entities in civil tax controversies, including sensitive audits, administrative appeals, and litigation, evaluating tax compliance options, internal investigations, and criminal tax investigations and prosecutions. During her tenure, the Tax Division reached agreements with 80 Swiss financial institutions that facilitated tax evasion and the avoidance of reporting requirements by U.S. account holders, and pursued suits to collect and defended challenges to FBAR penalties assessed by the IRS.  Ms. Ciraolo is Vice President of the American College of Tax Counsel, Chair of the Civil & Criminal Tax Penalties Committee of the ABA’s Section of Taxation, and an Adjunct Professor at 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).

Jeffrey Neiman, Founding Member, Marcus Neiman Rashbaum, Ft. Lauderdale, FL. Mr. Neiman is an experienced trial lawyer who regularly defends individuals and corporations in white collar criminal litigation, matters involving tax controversies, government regulatory enforcement matters, internal investigations, compliance counseling, and complex civil litigation. An alum of the United States Department of Justice Attorney General’s Honors Program, he began his career working for the Department of Justice Tax Division and then the Criminal Division, Fraud Section in Washington, D.C. He then served as an Assistant United States Attorney for the Southern District of Florida, where he received national recognition for handling complex, high profile matters including the ground-breaking and historic prosecution of Switzerland’s largest bank, UBS AG, for aiding American citizens to commit tax fraud.

Nicole M. Elliott, Partner, Holland & Knight, Washington, DC. Ms. Elliott is a tax attorney in Holland & Knight’s Public Policy & Regulation Group. Among her practice areas, Ms. Elliott advises clients on tax controversy matters, both at the administrative level and in litigation. Prior to joining Holland & Knight, Ms. Elliott was a tax litigator for the U.S. Department of Justice, Tax Division and a U.S. Treasury Department Executive and member of the senior executive team with the Internal Revenue Service, acting as Senior Advisor to Commissioner John A. Koskinen.

William M. Sharp, Sr. Partner, Holland & Knight, Atlanta, GA, Tampa, FL & San Francisco, CA. Mr. Sharp represents clients in a wide variety of international tax planning and tax controversy cases. He provides international and domestic tax advice to numerous U.S.-based and foreign-based clients, including publicly traded and closely held entities. His tax practice also focuses on globally oriented high-net-worth clients, including U.S. and foreign-based family offices. Mr. Sharp has served as lead counsel with respect to U.S. Tax Court, Internal Revenue Service (IRS) appeals and examination cases. He also has served as lead counsel or co-counsel to well over 1,000 IRS voluntary disclosure cases.

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