On August 20, 2021, Caroline D. Ciraolo participates in a panel entitled “Voluntary Disclosure Practice 2021 and Beyond” for the Texas Bar’s 39th annual Tax Law: Practicing Tax Law in Uncertain Times program.
Description: In light of the current and anticipated increase in civil and criminal tax enforcement, Caroline Ciraolo and Daniel Price review the IRS Relief Procedures for Former U.S. Citizens and the current Voluntary Disclosure Practice, including extensive updates to the Internal Revenue Manual provisions that address eligibility, the lookback period and penalty framework, cooperation requirements, and revocation procedures.
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