Caroline D. Ciraolo will speak at the International Bar Association’s Annual Conference being held Oct. 4-9, 2026, in Copenhagen, Denmark.
The IBA Annual Conference brings together leading international figures, government officials, general counsel, and experts from across all practice areas and continents to lead and participate in sessions that offer practical strategies and tools for international law practice.
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Caroline will speak on the following panels:
Monday, Oct. 5, 2026, 4:00 pm – 5:30 pm (Copenhagen Time)
What are the GAARdrails?
Caroline will co-chair this session in which panelists will discuss how courts and tax authorities have applied or attempted to apply anti-avoidance rules, whether in the form of a domestic General Anti-Avoidance Rule (GAAR), the principal purpose test (PPT), treaty-embedded Specific Anti-Avoidance Rules (SAARs), or the beneficial ownership test, to deny treaty or European Union Directive benefits. The discussion will explore the similarities and differences among these approaches and consider the point at which taxpayers appear to be falling over the anti-avoidance tax cliff.
Caroline will be joined by fellow co-chair Francesco Capitta of Facchini Rossi Michelutti, and speakers Sarah Blakelock of AstraZeneca, Dr. Aseem Chawla of New Delhi, India, Charlotte Kies of Loyens & Loeff, Matias Milet of Osler Hoskin & Harcourt LLP, and Arne Mollin Ottosen of Kromann Reumert.
Thursday, Oct. 8, 2026, 4:15 pm – 5:30 pm (Copenhagen Time)
Cross-border tax advice and criminal prosecution: is there still room for tax avoidance schemes?
The boundaries between legitimate tax planning and criminal tax evasion are increasingly under scrutiny. This panel will examine the criminal law risks associated with cross-border tax structuring and the evolving distinction between tax avoidance and criminal conduct. Topics include national and international approaches to criminal liability for aggressive tax planning, the reporting obligations of tax advisors and the mechanisms for information exchange and cooperation in cross-border investigations. The discussion will also address the institutions and legal instruments available to prosecutors and regulators confronting complex, multi-jurisdictional tax cases.
Caroline will be joined by session co-chairs George Pyromallis of the George Pyromallis Law Firm and Stefanie Schott of Kipper Durth Schott Rechtsanwälte, as well as fellow speakers Hannah Blecha of Schwärzler Attorneys at Law, Anke Feenstra of Hertoghs advocaten, Vikna Rajah of Rajah & Tann Singapore, and Anthony Thomas of Greenway Chambers.
About Caroline
Caroline is a former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division and a founder of the firm’s Washington, DC office. Her practice focuses on federal, state, and cross-border civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, and representing individuals and entities in criminal tax investigations and prosecutions. She also serves as a consulting and testifying expert witness and an independent mediator in tax disputes.
