Caroline D. Ciraolo was quoted in a recent Law360 article entitled “DOJ Official Sees Potential Uptick In Asset Repatriation Efforts,” published on May 12, 2021. Ciraolo continues a discussion that took place during the “Collection Abroad, Including Collection of Title 26 and Title 31 International Information Return Penalties” panel at the American Bar Association Tax Section’s Virtual May Meeting.
The article notes:
Caroline Ciraolo, a partner at Kostelanetz & Fink LLP who spoke during the panel, told Law360 on Wednesday that the U.S. is using treaty requests for a variety of purposes.
“While only six bilateral treaties with the United States contain mutual collection assistance provisions, the IRS is using treaty requests to obtain information regarding assets abroad and then pursuing those assets through, among other things, suits to repatriate the property,” she said.
As Ciraolo saw it, individuals intent on evading payment and obstructing efforts to collect run the serious risk of criminal investigation and prosecution.
“Bottom line: Taxpayers can run, but it is becoming increasingly difficult to hide,” she said. “A
proactive approach to address and resolve noncompliance is the better path.”