This study group will discus how a taxpayer's case traverses a criminal investigation including such topics as eggshell audits; the various types of privileges and supporting case law; distinguish between indicators of fraud and affirmative acts of fraud; how, and what causes, a taxpayer's case is referred to Criminal Investigations, along with signs that a referral is likely; explain the procedures and possible avenues within the criminal investigation process; and the most frequently charged tax crimes.
Moderators:
Caroline D. Ciraolo
Partner, Rosenberg Martin Greenberg,
LLP
Caroline D. Ciraolo defends
individuals and businesses in federal and state civil tax controversies, civil
tax litigation, and criminal tax investigations and prosecutions. She is a
Fellow of the American College of Tax Counsel, a member of the CJA Panel for the
U.S. Court of Appeals for the
4th Penalties Committee, and former Chair of the Tax Section of the
Maryland State BarAssociation.
Recent publications include Frequently Charged Tax
Crimes (2011); Effectively Representing Your Client Before the
IRS (Chapter 8, ABA Section of Taxation, 2011); and The Morning After - What You
Need to Know FBAR and International Information Returns Including Defending
Against and Litigating the Penalties," CCH's Journal of Tax
Practice & Procedure (October - November 2009).
Caroline is a 2010 recipient of
the ABA Janet R. Spragens Pro Bono Award, member of the Advisory Board, CCH
Journal of Tax Practice & Procedure, listed in Chambers USA (Nationwide -
Tax Fraud), named in Maryland SuperLawyers (2009-2012), Top 25 (2010,2011) and
Top 50 (2012) Women Attorneys in MD, and Top 50 (2011) and Top 100 (2012)
Attorneys in Maryland, and recipient of the Best Lawyers in America, 2012 Lawyer
of the Year - Litigation and Controversy - Tax (Baltimore, Maryland).
Education:
The College of New Jersey, B.S. in Finance (Honors) (cum
laude) (1990)
University of Maryland, School of Law, J.D. (Honors)
(1993)
University of Baltimore School of Law, LL.M. in Taxation
(1994)
Brian J.
Crepeau
Partner, Rosenberg Martin
Greenberg, LLP
Brian J. Crepeau
concentrates on federal and state tax controversy and litigation matters for
individual and corporate taxpayers. He represents clients in all
phases of administrative disputes before the Internal Revenue
Service and Comptroller of Maryland, and litigates tax cases before
the United States Tax Court.
Mr. Crepeau represents
corporations in complex audits, and provides tax planning advice on a
wide range of issues. His controversy and litigation expertise and
experience extends to all areas of federal income taxation as well
as state and local tax matters. As Certified Public Accountant and
a Certified Fraud Examiner he is particularly skilled in cases involving
accounting practice and procedures and fraud.
Before graduating from law
school, Mr. Crepeau worked for a regional public accounting firm,
PG&E Corporation and a global consulting firm. In this capacity
he has advised private and public companies across multiple
industries on SEC and financial reporting, taxation matters and Sarbanes-Oxley
issues.
Prior to joining the firm
in 2008, Mr. Crepeau practiced in Annapolis, Maryland and acted as a
consultant to international law firm's on accounting fraud, SEC
investigations, revenue recognition issues, fraudulent business
mergers and acquisitions, and tax fraud and evasion.
Practice Areas:
Federal and State Tax
Controversies and Litigation
Criminal Tax
Defense
Business and Transactional
Matters
Estates and
Trusts
Memberships/Affiliations:
Maryland State Bar
Association
Anne Arundel Bar
Association
American Associate of
Attorney-Certified Public Accountants
American Institute of
Certified Public Accountants
Maryland Association of
Certified Public Accountants
Association of Certified
Fraud Examiners
Bar Admissions:
Maryland
U.S. Tax Court
Education:
Bridgewater State
University, B.S. in Management Science-Accounting (1997)
American
University, Washington College of Law, J.D. (2003)
Awards:
2011-2012 FIVE STAR Wealth
Manager Award Winner
Martindale-Hubbell® Peer
Review Rated - AV® Preeminent™
Maryland Super Lawyers
Rising Star (2012) - Tax