Caroline D. Ciraolo speaks on “Ethics: When Aggressive Tax Planning and Controversy Defense Become Criminal Conduct” at the 71st Tulane Annual Tax Institute on November 17th, 2022.

Taxpayers frequently look to minimize their tax burdens or avoid immediate payment of tax liabilities and tax professionals often assist with a variety of planning structures or defensive strategies. It is when these structures or strategies cross the line that the Government sounds the alarm. On the civil side, tax-advantaged transactions or aggressive collection strategies that are “to good to be true,” “lack economic substance,” or “lack business purpose” can result 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 investigation, 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.

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