DOJ Tax Division and IRS Officials Describe Civil Tax Enforcement Priorities

CE1512CTF Print Brochure_1Speaking at the ABA’s Annual Criminal Tax Fraud and Tax Controversy Conference, senior officials from the Tax Division of the Department of Justice (DOJ) and the IRS Office of Chief Counsel described a variety of priorities for civil enforcement.

Consistent with prior indications that payroll taxes will be a significant area of focused criminal enforcement, Diana L. Erbsen, Deputy Assistant Attorney General for Appellate and Review, indicated that practitioners should anticipate civil actions for injunctive relief in payroll tax cases, followed by contempt proceedings to enforce those injunctions. Erbsen also indicated that the Financial Litigation Unit of the Office of Review, which focuses on collecting tax judgments, has received additional staff and is expected to be more active.… Read More

A Conversation with UVA Law’s Brandon Garrett About the DOJ’s Swiss Bank Program

Brandon L. GarrettRecently I had the opportunity to speak with my former law professor, Brandon Garrett, about the DOJ’s Swiss bank program. Professor Garrett is the Justice Thurgood Marshall Distinguished Professor of Law at the University of Virginia School of Law, and author of the recent book Too Big to Jail: How Prosecutors Compromise with Corporations. Professor Garrett has written and spoken extensively about white collar corporate prosecutions and the use of non-prosecution and deferred prosecution agreements in the corporate prosecution context.

A little background to our conversation. The DOJ’s Swiss bank program provides in part a path for Swiss banks that believe that they may have committed tax-related criminal offenses in connection with undeclared bank accounts held by U.S.… Read More

Employers Beware: AAG Ciraolo Emphasizes Employment Taxes as Enforcement Priority

Department of Justice

U.S. Department of Justice places employment taxes high on its list of enforcement priorities

We had the pleasure today of hearing the comments of Caroline Ciraolo, Acting Assistant Attorney General (AAG) for the Tax Division of the U.S. Department of Justice (DOJ), regarding DOJ Tax Division’s current enforcement priorities. Acting AAG Ciraolo provided one of the keynote addresses at the American Law Institute’s Continuing Legal Education conference, Handling a Tax Controversy: Current Trends in Civil Tax Controversies and Litigation, held in Washington, D.C. This blog entry will focus on, just as Acting AAG Ciraolo did, the issue of employment tax enforcement.… Read More