American Citizens Abroad TaxCast

Marie Sapirie is a contributing editor for Tax Notes, a nonprofit tax publisher, where she writes about federal taxation. Prior to joining Tax Notes, she practiced tax law at Covington & Burling and served as a law clerk for Judge D. Brooks Smith of the United States Court of Appeals for the Third Circuit and Judge Glen E. Conrad of the United States District Court for the Western District of Virginia. Marie received her JD from William & Mary Law School and her undergraduate degree from Georgetown University. Prior to law school she taught at a middle school in Japan. Charles Bruce is Chairman of American Citizens Abroad Global Foundation and Legal Counsel of ACA. He is an American tax lawyer and practiced in Washington, DC, London and Lausanne. He currently divides his time between Washington and London. At various times he served on the tax staff of the US Senate Finance Committee and taught tax law at Institut für Ausländisches und Internationales Finanz- und Steuerwesen, Hamburg University, Hamburg, and in the Graduate Law Program, Georgetown University Law Center, Washington, DC. "How the Senate’s Rules and Precedents Shape the Tax Law" by Marie Sapirie [https://www.americansabroad.org/media/files/page/09cdbd52/sapirie-how-the-senate-s-rules-and-precedents-shape-the-tax-law-tax-notes-03-15-2021-.pdf] Concurrent Resolution [https://www.democrats.senate.gov/imo/media/doc/HEN21B52.pdf] Donate to ACAGF's Educational and Research Work in Support of Residence-Based Taxation [https://www.acaglobalfoundation.org/donate]

Glen Frost, Assistant ACA Legal Counsel and Marylouise Serrato, ACA Executive Director give an update on the changes in the Child Tax Credit (CTC) included in the recently passed legislation, American Rescue Plan. Child Tax Credit [https://www.irs.gov/credits-deductions/advance-child-tax-credit-payments-in-2021]

We chat with Marylouise Serrato, Executive Director of American Citizens Abroad, about how the CARES Act stimulus and economic support has been working for Americans living and working overseas and how the problems American expats have encountered with the support can help with getting Residency-based Taxation legislation passed. American Citizens Abroad Memorandum to Congress, Treasury and IRS: Payment of 2020 Recovery Rebates to Individuals Abroad [https://www.americansabroad.org/news/aca-memo-to-congress-treasury-and-irs-payment-of-2020-recovery-rebates-to-individuals-abroad/] State Department Federal Credit Union and ACA Ready to Help Americans Overseas Receive Rebate Recovery Payments [https://www.americansabroad.org/news/sdfcu-and-aca-ready-to-help-americans-overseas-receive-rebate-recovery-payments/] Tax Fairness for Americans Abroad: An Idea Worth Fighting For! [https://acacampaign.today/hearings] Learn More about the Tax Fairness for Americans Abroad: An Idea Worth Fighting For Campaign [https://acacampaign.today/LearnMore] International Postal Service Disruptions [https://about.usps.com/newsroom/service-alerts/international/welcome.htm] IRS Economic Impact Payment Information [https://www.irs.gov/coronavirus/economic-impact-payment-information-center] IRS Phone numbers: 1-800-829-1040 US-based number (267) 941-1000

Part 2 of our interview with Caroline Ciraolo, partner with Kostelanetz & Fink and former Acting Assistant Attorney General of the US Department of Justice's Tax Division, we take a deeper dive into the types of tax professionals and government officials that may play a role in a client’s tax matters, the nature and risks of an “eggshell” audit, the scope of applicable privileges, best practices for vetting clients and managing an examination or investigation, and much more. Caroline’s practice focuses on civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, and representing individuals and entities in criminal tax investigations and prosecutions. During her tenure with the Justice Department, Caroline was actively involved in all aspects of Tax Division operations and responsible for approximately 500 employees, including more than 360 attorneys in 14 civil, criminal and appellate sections.  Under her leadership, the Division reached agreements with 80 Swiss financial institutions that admitted to facilitating tax evasion and the avoidance of reporting requirements by U.S. accoun tholders, increased civil and criminal enforcement with respect to offshore tax evasion, employment tax violations, and traditional tax offenses, assisted the IRS through summons enforcement proceedings, and engaged in affirmative and defensive litigation involving abusive tax shelters and schemes, refund claims, and challenges to statues and regulations. Caroline is Vice President of the American College of Tax Counsel, Chair of the Civil and Criminal Tax Penalties Committee of the American Bar Association’s Section of Taxation, and an Adjunct Professor at the Georgetown University Law Center (International Tax Controversies, Tax Fraud and Tax Crimes) and University of Baltimore School of Law Graduate Tax Program (Investigation, Prosecution and Defense of Tax Crimes). Click here to read Caroline’s full bio [https://www.kflaw.com/caroline_d_ciraolo] Charles Bruce is Legal Counsel of ACA, Chairman of ACA’s sister organization, ACA Global Foundation, former Tax Counsel of the Senate Finance Committee, Adjunct Professor of Law at Georgetown University Law Center, in Washington, and Visiting Professor, Institute of Foreign and International Finance and Taxation, Hamburg University. He divides his time between London and Washington DC. Listen to Part 1 of our interview [https://acareturnpreparerdirectory.com/aca-taxcast.html]orhere [https://www.youtube.com/playlist?list=PLzVGl8FmddC8iS9O_yMgbjJSFnPMOjSOi]

We speak with Caroline Ciraolo, partner with Kostelanetz & Fink and former Acting Assistant Attorney General of the US Department of Justice’s Tax Division, and Charles Bruce, Legal Counsel of American Citizens Abroad and Chairman of American Citizens Abroad Global Foundation about non-filers and the CARES Act stimulus payments, voluntary disclosure, streamlined filing compliance procedures, delinquent international information return submission procedures, and more! Caroline’s practice focuses on civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation, providing tax advice, conducting internal investigations, and representing individuals and entities in criminal tax investigations and prosecutions. During her tenure with the Justice Department, Caroline was actively involved in all aspects of Tax Division operations and responsible for approximately 500 employees, including more than 360 attorneys in 14 civil, criminal and appellate sections.  Under her leadership, the Division reached agreements with 80 Swiss financial institutions that admitted to facilitating tax evasion and the avoidance of reporting requirements by U.S. accountholders, increased civil and criminal enforcement with respect to offshore tax evasion, employment tax violations, and traditional tax offenses, assisted the IRS through summons enforcement proceedings, and engaged in affirmative and defensive litigation involving abusive tax shelters and schemes, refund claims, and challenges to statues and regulations. Caroline is Vice President of the American College of Tax Counsel, Chair of the Civil and Criminal Tax Penalties Committee of the American Bar Association’s Section of Taxation, and an Adjunct Professor at the Georgetown University Law Center (International Tax Controversies, Tax Fraud and Tax Crimes) and University of Baltimore School of Law Graduate Tax Program (Investigation, Prosecution and Defense of Tax Crimes). Click here to read Caroline’s full bio [https://www.kflaw.com/caroline_d_ciraolo] Charles Bruce is Legal Counsel of ACA, Chairman of ACA’s sister organization, ACA Global Foundation, former Tax Counsel of the Senate Finance Committee, Adjunct Professor of Law at Georgetown University Law Center, in Washington, and Visiting Professor, Institute of Foreign and International Finance and Taxation, Hamburg University. He divides his time between London and Washington DC. IRS May 11 2018 Webinar [https://www.irsvideos.gov/Business/FilingPayingTaxes/StreamlinedFilingComplianceProceduresAComplianceOptionForSomeTaxpayers] Court Grants IRS Summons of Coinbase Records [https://www.journalofaccountancy.com/issues/2018/mar/irs-summons-of-coinbase-records.html] Brian Booker, Former CPA, Indicted for Failing to Report Foreign Bank Accounts and Filing False Documents with the IRS [http://www.madisonfl.net/blog/brian-booker-ft-lauderdale-former-cpa-indicted-for-failing-to-report-foreign-bank-accounts-and-filing-false-documents-with-the-irs/] US Professor Hit with US$100M FBAR Penalty for Hiding US$200M in Assets [https://www.internationalinvestment.net/internationalinvestment/news/3505014/us-professor-hit-ususd100m-fbar-penalty-hiding-ususd200m-assets] United States of America, Appellee, v. Louis Kovel, Defendant-appellant, 296 F.2d 918 (2d Cir. 1961) [https://law.justia.com/cases/federal/appellate-courts/F2/296/918/131265/]