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UNDERSTANDING THE SCOPE OF PRIVILEGES IN CROSS-BORDER AUDITS AND INVESTIGATIONS

CPE Processing Fee$15.00
Webinar TranscriptionN/A
Presentation Length Hour(s)1.5 hours
CPE1.5
1 hour for EAs (Federal Tax Update)
Course Id# - HURS9-U-00482-19-S
Subject AreaTaxes
Course LevelBasic
Instructional MethodQAS Self-Study
PrerequisitesNone
Advance PreparationNone
Recorded DateJun 20, 2019
Date OfferedAug 07, 2019
Course Description

International tax enforcement is a top priority of the IRS and the Department of Justice. Audits and investigations routinely involve the collection of information, documents, and testimony outside the United States, leaving tax practitioners to determine what, if any, privilege applies and how those privileges can be preserved in various jurisdictions.

This panel of experienced tax controversy attorneys addresses common privileges that arise in tax matters, the holder and scope of those privileges, the extent to which such privileges can be waived or set aside, and how to navigate these waters in foreign and cross-border audits and investigations.

Learning Objectives

  • Identify situations in which a taxpayer’s information might be privileged, as well as situations that lead to privilege being lost, waived, not applicable.

9
Handout Materials
Presentation Slides
Review Questions
Review Questions
QUESTION 1: 0:15:00 minutes
QUESTION 2: 0:28:00 minutes
QUESTION 3: 0:55:00 minutes
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Caroline D. Ciraolo, former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division, is a partner with Kostelanetz & Fink and a founder of its Washington, D.C. office.  Her practice focuses on complex and sophisticated civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation in federal and state courts and tax tribunals, providing related tax advice, including advice on uncertain tax positions, financial reporting, claims for refund, amended returns, voluntary disclosures, and internal investigations, and representing individuals and institutions in criminal tax investigations and prosecutions.

Mark Daly

U.S. Department of Justice - AFMLS
Litigation Counsel, Tax Division
mark.f.daly@usdoj.gov
(202) 616-2245

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Caplindrysdale

Mark D. Allison is a Member in Caplin & Drysdale's New York office. Mr. Allison’s clients include multinational corporations, financial institutions, sovereign wealth funds, global high-net-worth individuals, and professional athletes and entertainers. He has substantial industry experience in financial services, healthcare, utilities, and infrastructure.

Carolyn Schenck

IRS
Assistant Division Counsel (International)

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CAROLYN A. SCHENCK has been employed by the Internal Revenue Service Office of Chief Counsel for 13 years.  She is currently Assistant Division Counsel (International) in the Small Business/Self Employed Division and has been assigned for the last 11 as counsel to the Service’s Offshore Compliance Initiatives.  Carolyn is responsible for coordination and management of all international and offshore tax and Report of Foreign Bank and Financial Accounts (FBAR) matters under the jurisdiction of SB/SE Division Counsel.  She ensures that SB/SE attorneys consistently apply law and policy in international and offshore tax and FBAR matters, including non-docketed cases and cases docketed in the U.S. Tax Court, U.S. District Courts, the Court of Federal Claims, and the U.S. Courts of Appeals.  Carolyn also provides guidance to and serves as the principal legal advisor and contact point on international and offshore tax and FBAR matters to the SB/SE Division and the Withholding and International Individual Compliance function of the LB&I Division.  Her international work also involves John Doe summons actions, the Service’s Offshore Voluntary Disclosure programs and Streamline Filing Compliance Procedures, working with IRS Treaty partners on cross-border issues and cases, and conducting nationwide trainings for attorneys and agents on investigative techniques, evidence, and substantive tax issues.  She has litigated numerous cases in U.S. Tax Court on behalf of the IRS. She also works with IRS special enforcement agents on cases involving fraud, foreign accounts, and foreign reporting penalties; she also assists the Department of Justice in cases involving criminal tax prosecutions, injunctions, summons enforcement, and abusive tax return preparers and promoters.  She has been an Adjunct Professor at Pepperdine University School of Law for Honors Appellate Advocacy.  Prior to joining the IRS, she was an Attorney for the Securities and Exchange Commission, Division of Enforcement.  She also worked for Chief Judge Alex Kozinski of the Ninth Circuit and Chief Judge H. Robert Mayer of the Federal Circuit Courts of Appeals.  Before her law career, Ms. Schenck worked for U.S. Senator John McCain and as a weapons analyst.  She is a member of the California and Maryland state bars and holds a J.D. from Pepperdine University School of Law, and a B.S. summa cum laude from Northern Arizona University.

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Sarah joined Eversheds Sutherland from the United States Attorney’s Office for the Southern District of New York, where she served for over nine years as an Assistant United States Attorney in the Criminal Division. As a member of the Complex Frauds and Cybercrime Unit for nearly six years, she worked on sophisticated white-collar cases involving the investigation and prosecution of institutions and individuals for a variety of financial crimes, including Foreign Corrupt Practices Act violations, wire fraud, bank fraud, cybercrime, international money laundering, securities fraud, health care fraud, and Bank Secrecy Act violations. She also served in the Money Laundering and Asset Forfeiture Unit, where she litigated substantial asset forfeiture matters, including significant art fraud cases.

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About Our Presenter

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For nearly 85 years, the NYU School of Professional Studies has been a deeply respected institution of higher education that is grounded in applied learning. It has served as a source of empowerment for individuals from NYC, across the country, and around the world, who aspire to become the next generation of leaders and innovators of industry.

Throughout its rich history, NYUSPS has met the needs of the students and the professional communities it serves. From its early years, training returning World War II veterans to fulfill the nation’s urgent need for skilled technical workers, it has evolved into a professional education powerhouse that offers 19 graduate degrees, 13 bachelor’s degrees, four associate’s degrees, and a plethora of non-degree courses and credentials. It is focused on building skills that open doors to opportunities in emerging fields and global markets.