This spring, Caroline Ciraolo and Victor Jaramillo will 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 Jaramillo will concentrate the course on real world civil and criminal tax controversies involving international tax matters facing today’s tax practitioners.
The course focuses 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 transactions.
Ms. Ciraolo previously served as Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division, where she was actively involved in all aspects of Tax Division operations and responsible for approximately 500 employees, including more than 360 attorneys in 14 civil, criminal and appellate sections.
Mr. Jaramillo is a Member at Caplin & Drysdale, Chtd’s Washington, D.C. office and is a member of the firm’s Board of Directors. He has experience advising multinational corporations, financial institutions, and individual clients on a broad range of tax matters, including tax controversies, risk management and international compliance, and cross-border structuring.
Kostelanetz LLP is proud to be training the next generation of tax lawyers by sharing with law students the important lessons they have learned from decades of representing a wide variety of corporations, institutions, and individuals in complex tax matters.
Click here for more information about Georgetown Law’s tax curriculum. The course will be held on Monday evenings, from 7:55 PM to 9:55 PM on a hybrid basis.
