Page 1 - International Enforcement: What’s Old, What’s New and What We Can Expect
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International Enforcement: What’s



           Old, What’s New and What We



           Can Expect






           By Caroline D. Ciraolo

           At the 35th Annual UCLA Extension Tax Controversy Institute,

           Caroline D. Ciraolo and her fellow panelists addressed

           international tax compliance and enforcement, including what’s

           old, what’s new and what we can expect going forward.











                                                         e cannot continue to operate in the same ways we have in the
                                                         past, siloing our information from the rest of the world while
                                            “W organized criminals and tax cheats manipulate the system and
                                            exploit vulnerabilities for their personal gain. The J5 [Joint Chiefs of Global Tax
                                            Enforcement] aims to break down those walls, build upon individual best practices,
                                            and become an operational group that is forward-thinking and can pressurize
                                            the global criminal community in ways we could not achieve on our own.” Don
                                            Fort, Chief of IRS Criminal Investigation (July 2, 2018).
                                              International tax compliance and enforcement continue to be top priorities of
                                            the Internal Revenue Service (“IRS”) and the U.S. Department of Justice (“DOJ”)
                                            Tax Division. In October 2019, IRS Criminal Investigation (“CI”) employed
                                            2,030 special agents, down from its high water mark of 3,363 special agents in
                                            1995, but these agents are expert financial investigators and are focusing on high
                                            impact cases with strong general deterrence. In Fiscal Year 2019, CI initiated 2,485
                                            investigations, recommended 1,893 prosecutions, and assisted DOJ in obtaining
                                            1,800 indictments and information. Of the investigations initiated during this
           CAROLINE D. CIRAOLO, former      period, 214 involve international enforcement issues.
           Acting Assistant Attorney General   Cross border investigations are often the most complex and time consuming
           of the U.S. Department of Justice’s   matters in CI’s inventory. These investigations are supported by the CI attaches,
           Tax Division, is a partner with   deputy attaches, and investigative aides based in 11 countries, including Germany
           Kostelanetz & Fink and a founder of   (Frankfurt), China (Hong Kong), England (London), Australia (Sydney), the
           its Washington, D.C. office.
                                            Netherlands (the Hague), Colombia (Bogota), Barbados (Bridgetown), Mexico
                                            (Mexico City), Canada (Ottawa), UAE (Dubai), and Panama (Panama City).


           SPRING 2020                                                                         © 2020 C.D. CIRAOLO  49
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