On May, 28, 2021, Caroline D. Ciraolo participates in a panel entitled “Criminal Investigations and Civil Tax Audits” at the Center For Taxpayer Rights 5th International Conference on Taxpayer Rights: Quality Tax Audits and the Protection of Fundamental Rights.

Description: As tax agencies ramp up enforcement efforts, including cooperating internationally, the dividing line between civil tax audits and criminal investigations becomes blurred. This panel will explore the practices of various countries, considering whether the audit and criminal investigation run concurrently, whether there is a mens rea requirement for criminal tax sanctions, the application of the principle of proportionality, and the deterrent function of criminal sanctions. How are civil fraud penalties integrated with criminal sanctions. At what point is the taxpayer notified it is a target of criminal investigation? What is the overlap between tax audits and anti-money laundering initiatives and legislation?

Moderator: Nicolas Michon, Juge au Tribunal Judiciaire de Paris, France

Panelists: Caroline Ciraolo, Kostelanetz & Fink, LLP, United States – David Hummel, Legal Secretary, Court of Justice of the European Union, Luxembourg; Professor, University of Leipzig, Germany – Eleonor Kristoffersson, Professor, School of Law, Psychology and Social Work, Örebro University; Visiting Professor, Linköping University and Gävle University, Sweden

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