On November 2, 2016, Principal Deputy Assistant Attorney General Caroline D. Ciraolo delivered remarks at the American Bar Association Philadelphia Tax Conference.  After providing statistics on the DOJ Tax Division’s civil and criminal cases over the last two years, Ciraolo turned to the Tax Division’s current areas of focus.  Ciraolo noted that civil and criminal employment tax enforcement is among the Tax Division’s top priorities.  Ciraolo stated that the Tax Division has filed injunction complaints “to send a clear message to delinquent employers who treat taxes withheld from employee wages as a personal slush fund or loan that can be put off or ignored entirely,” and is also “prioritizing criminal investigations and prosecutions of willful employment tax violations.”  Ciraolo then discussed the Tax Division’s criminal offshore enforcement efforts, and noted that these “efforts have encouraged participation in the IRS offshore voluntary disclosure programs.”  Ciraolo also noted that current priorities include challenging “tax shelters designed to generate large tax benefits using multiple entities and complex financial institutions that, in the government’s view, lack a real business purpose or any real economic substance.”  Looking ahead to 2017, Ciraolo stated that “the Tax Division is now well into the legacy phase of the Swiss Bank Program, reviewing the substantial data provided by the banks and obtained from other sources.”  Ciraolo added: “We are following the money outside Switzerland and into jurisdictions around the world and investigating activities by asset management companies, corporate service providers, financial advisers, insurance companies and other financial entities.”  Ciraolo also stated that in “corporate civil and criminal investigations, you will continue to see an emphasis on individual accountability,” and that prosecuting a corporation “is not a substitute for the prosecution of criminally culpable individuals.”  She noted: “Failure to come forward and identify individual actors will render an entity ineligible for cooperation credit.”  Finally, Ciraolo stated that, while the Tax Division is not announcing the creation of a Tax Division whistleblower office, “if a whistleblower is truly interested in bringing attention to illegal conduct and schemes that undermine our nation’s tax system, the Tax Division welcomes and is prepared to receive such information.”  DOJ Press Release