On September 22, 2021, Caroline D. Ciraolo participates in a panel entitled “John Doe Summonses: The Tool to Close the Crypto Compliance Gap and Implications for Privilege” for the American Bar Association Section of Taxation’s Virtual Fall Meeting. The meeting is a five-day event led by the country’s leading tax attorneys and government officials, discussing the latest federal, state, and local tax policies and more.

Description: A John Doe Summons allows the IRS, with court approval, to obtain information from a third-party about a class of taxpayers. The IRS’s use of these summonses to identify account holders of UBS made headlines in 2008. Since then, the IRS has expanded the use of John Doe Summonses as an available investigatory tool, including on domestic cryptocurrency exchanges. This panel will recount the historical use of John Doe Summonses by the IRS; examine areas in which the IRS is currently employing these summonses and where they can be used in the future; and discuss important privilege issues that may raise, an example of which is currently pending before the U.S. Supreme Court in Taylor Lohmeyer Law Firm v. United States (Docket 20-1596). The panel’s participants are as follows:

Moderator

• Victor Jaramillo, Caplin & Drysdale, Washington D.C.

Panelists

• Honorable Steven D. Grimberg, United States District Judge, Northern District of Georgia;
• Lawrence Hill, Steptoe & Johnson, New York, NY;
• Jeffrey Neiman, Marcus Neiman Rashbaum & Pineiro, Ft. Lauderdale, FL; and
• Caroline Ciraolo, Kostelanetz & Fink, Washington, D.C.

Click here for more information and to register.