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Caroline D. Ciraolo and Don Fort Participate In A Panel Titled “When Aggressive Tax Planning Becomes Criminal Conduct” At The 59th Annual Hawaii Tax Institute
November 10, 2022 @ 12:30 pm - 1:30 pm HST
High income taxpayers frequently look to minimize their tax burdens and tax professionals are only too happy to oblige with one planning structure or another. It is when these structures cross the line that the Government sounds the alarm. When tax-advantaged transactions are “too good to be true,” “lack economic substance,” “lack business purpose,” or are deemed to be economic scams, taxpayers and their advisors can face civil audits and promoter investigations, both resulting in substantial civil penalties, professional licensing issues, and injunctions. When the Government believes that the individuals involved intentionally violated the rules – lying, cheating, or stealing – the matter can quickly move into the criminal realm. This panel will review what causes the Government to initiate a criminal tax investigations, ethical considerations for wealth transfer advisors, the roles of IRS-CI, the Justice Department’s Tax Division, and the U.S. Attorney’s Office, the transactions and structures currently targeted by the IRS, and “ripped from the headlines” criminal tax prosecutions.
- Caroline D. Ciraolo, Partner, Kostelanetz LLP
- Don Fort, Director of Investigations, Kostelanetz LLP
- Evan Davis, Principal, Hochman Salkin Toscher Perez PC
- Rebecca Perlmutter, AUSA, U.S. Attorney’s Office, District of Hawaii
Click here to register. Please note the event will be taking place in PST time.