This spring, Caroline Ciraolo and Robert Russell will again bring their decades of experience in federal tax enforcement and tax controversy matters to Georgetown University Law Center and Graduate Tax Program in a class entitled, “International Tax Controversy.” Professors Ciraolo and Russell concentrate the course on real world civil and criminal tax controversies involving international tax matters facing today’s tax practitioners.
Beginning with an introduction to the U.S. compliance regime — including the obligation to report worldwide income, specified foreign financial assets, and international business activity — students learn the various international tax reporting obligations, applicable statutes of limitations and tolling provisions, potential civil penalties under the Internal Revenue Code and the Bank Secrecy Act, options for resolving non-compliance, procedures for challenging proposed and assessed penalties, and the risk and current landscape of criminal tax investigations and prosecutions. The course also includes a study of current international enforcement and litigation trends involving cross-border business transactions and base erosion/profit shifting issues.
Click here for more information about Georgetown Law’s tax curriculum.
