How States Are Closing the Crypto Tax Gap

Carolyn assists corporations, individuals, families, trust companies, and tax professionals with criminal and civil tax enforcement and compliance matters. Specifically, she helps clients navigate compliance issues even before IRS involvement, as well as advising clients on civil examinations, summons and subpoena matters, tax and penalty issues, sensitive audits and fraud cases, criminal tax investigations, and related litigation.

Carolyn is as an accomplished senior government leader with almost 20 years of experience directing high-impact enforcement, compliance and litigation programs at the IRS, and partnering extensively with the Department of Justice on major financial fraud initiatives and cases. She is nationally recognized for her deep expertise in tax controversy, civil fraud, digital assets, and matters involving complex financial crimes, and she brings a unique blend of litigation and policy experience to the private practice. As the IRS’s first-ever National Fraud Counsel, Carolyn played a pivotal role in establishing the position and teams of specialists, and she partnered closely with the newly-created Office of Fraud Enforcement – the first of its kind – to build a revitalized national program focused on civil and criminal tax fraud, advising on the design and execution of Service-wide initiatives to detect and deter fraud, including digital assets. While serving as the Senior Level Counsel (Offshore), Carolyn spearheaded the IRS’s efforts to combat offshore tax evasion. She led an IRS Counsel team to advise the Commissioner’s Offshore Compliance Initiative, oversaw 60+ John Doe summons actions involving banks, digital assets, offshore service providers, wealth advisors and other entities, and worked closely with DOJ on the Swiss Bank Program and multiple offshore prosecutions. She served as counsel to the Offshore Voluntary Disclosure Program, IRS-Criminal Investigation’s Voluntary Disclosure Practice, and Streamlined Filing Procedures. She also stood up Chief Counsel’s Digital Assets Cadre.