On May, 12, 2021, Caroline D. Ciraolo participates in a panel entitled “Collection Abroad, Including Collection of Title 26 and Title 31 International Information Return Penalties” at the American Bar Association Section of Taxation Virtual May Meeting.
Description: With the increase in international enforcement efforts, heightened focus on anti-money laundering and anti-tax evasion, and recent clarifications to the Delinquent International Information Return Submission procedures, individuals and entities are increasingly subject to substantial civil penalties for failing to report foreign financial accounts and other violations of the Bank Secrecy Act and the Internal Revenue Code. This panel will review the methods by which the United States can collect penalties assessed under the Bank Secrecy Act and the Internal Revenue Code, available defenses, and best practices for pursuing collection alternatives. The panelists will also discuss other collection devices available to the Government to collect taxes from abroad, including: writ ne exeat republica actions and customs or prevent departure orders; repatriation orders; receiverships; and mutual collection assistance requests under applicable treaties.
Moderator: Eli S. Noff, Frost Law, Annapolis, MD
Panelists: Frank Agostino, Agostino & Associates, PC, Hackensack, NJ; Caroline D. Ciraolo, Kostelanetz & Fink LLP, Washington, DC; Daniel N. Price, IRS Office of Chief Counsel (Small Business/Self Employed), Austin, TX; Thomas J. Sawyer, U.S. Department of Justice, Tax Division, Washington, DC
Click here for more information and to register.