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Compliance Initiatives and Voluntary Disclosure Practice-Perspectives and Updates from Puerto Rico's Hacienda and the IRS

Level: Advanced
Runtime: 138 minutes
Recorded Date: September 09, 2021
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  • Puerto Rico Economic Incentive Programs
  • Puerto Rico Taxation and Use of Incentives
  • Compliance Efforts –Hacienda’s Perspectives
  • Incentive and Compliance Efforts –IRS’s Perspectives
  • Puerto Rico Compliance Options and Voluntary Disclosures
  • U.S. Compliance Options and Voluntary Disclosures
Runtime: 2 hours, 18 minutes
Recorded: Recorded: September 9, 2021

Difficulty: Experienced Attorneys (Non-Transitional)


In light of the current and anticipated increase in civil and criminal tax enforcement, and the new IRS and PR campaigns to address taxpayers who have claimed benefits through Puerto Rican residency and incentive programs, this panel will review the history and background of Puerto Rico Acts 20 and 22, the use and abuse of these programs from the IRS and PR perspective, respectively, potential civil penalties, current enforcement efforts, and potential paths to compliance, including the IRS Voluntary Disclosure Practice and Hacienda’s Voluntary Disclosure Practice. Panelists include key personnel within the Internal Revenue Service and Departamento de Hacienda de Puerto Rico.

This program was recorded on September 9th, 2021.

Provided By

American Bar Association
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Ladd C. Brown, Jr.

Senior Counsel
Internal Revenue Service

Ladd C. Brown, Jr. is a Senior Counsel at the Internal Revenue Service.                                                

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Lucille Nicole Rivera-Mari, Esq.

Special Assistant, Office of Incentives for Businesses in Puerto Rico
Department of Economic Development and Commerce

Lucille Nicole Rivera-Mari, Esq. is the Special Assistant at the Office of Incentives for Business in Puerto Rico at the Department of Economic Development and Commerce of Puerto Rico. She earned his JD at the Inter-American University School of Law in 2013.

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Carlos Fontan

Director, Office of Incentives for Businesses in Puerto Rico
Department of Economic Development and Commerce

Carlos Fontan is the Director of the Office of Incentives for Businesses in Puerto Rico at the Department of Economic Development & Commerce. He earned his JD at the University of Puerto Rico School of Law.

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Angel Pantoja-Rodriguez

Deputy Secretary
Puerto Rico Department of Treasury

Angel Pantoja-Rodr?guez is the Deputy Secretary of the Puerto Rico Department of the Treasury (“Department”). He advises and assists the Secretary of the Treasury in the supervision and direction of the Department and its activities and succeeds the Secretary in his absence or unavailability. As Deputy Secretary of Treasury, Angel plays a primary role in the formulation and execution of the Department’s policies and programs in all aspects of the Department's duties and responsibilities, which include overseeing the implementation of tax revenues initiatives and fiscal measures established under the Puerto Rico Oversight, Management, and Economic Stability Act (“PROMESA”).

Prior to his current designation, at a mere 30 years of age, Angel was appointed as Assistant Secretary for Internal Revenue and Tax Policy Areas at the Department, after serving as Deputy Assistant Secretary for such areas for more than two years.

During his term as Assistant Secretary, he served as a main advisor to the Secretary in tax policy matters and was responsible for administering and supervising the execution and application of the state Internal Revenue Code and other local tax laws, such as the Puerto Rico Code of Tax Incentives. He also played a lead role in the complete digitalization of the tax administration system at the Department, commonly known as the “Unified Internal Revenue System” (“SURI”, by its spanish acronym).

Prior to joining the Department in 2017, Angel worked as an attorney at Marichal, Hern?ndez, Santiago & Juarbe, LLC, where he represented and provided counsel to privately held businesses on a broad range of issues, including mergers and acquisitions, commercial litigation, corporate and tax law.

Angel is an attorney-at-law, and he holds a Bachelor’s Degree in Business Administration from the University of Puerto Rico and a Juris Doctor from the Pontifical Catholic University School of Law. He is currently in process of completing an MBA in Accounting, as well as obtaining a license to practice as a Certified Public Accountant (CPA).

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Daniel N. Price

Attorney, Office of Chief Counsel
U.S. Dept. of Treasury

Daniel N. Price is an attorney with the Office of Chief Counsel of the Internal Revenue Service (SB/SE Division) in Austin, Texas. Dan advises the IRS on national issues relating to Offshore Voluntary Disclosure Programs and the Streamlined Filing Compliance Procedures. His role in these special compliance initiatives includes planning, developing, and writing FAQs for public guidance, developing new forms, speaking at practitioner events, training and advising IRS personnel, developing job aids and templates, and much more.

Dan has a tax litigation background and also handles complex cases involving tax fraud and willful FBAR violations. Dan received an undergraduate degree in accounting, summa cum laude, from the University of Texas at San Antonio, and a master’s degree in accounting from Trinity University.

Dan received his J.D., with honors, from the University of Texas School of Law. During the first year of law school, Dan passed the Uniform CPA exam (not licensed as a CPA).

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Caroline D. Ciraolo

Kostelanetz & Fink LLP

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. account holders, and imposed and collected more than $1.36 billion in penalties, 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 statutes and regulations.

Prior to joining the Department, Caroline was Chair of the Tax Controversy and Litigation practice group of a regional firm in Baltimore, Maryland, where she represented individuals and businesses in all phases of state and federal civil tax controversies and criminal tax investigations and prosecutions. She has appeared before the IRS, the Comptroller of Maryland and the D.C. Office of Tax and Revenue, the Maryland Tax Court, the U.S. Tax Court, U.S. District Courts, the Maryland circuit and appellate courts and the U.S. Court of Appeals for the Fourth and Federal Circuits.

Caroline is a Fellow and Officer of the American College of Tax Counsel and Chair of the Civil and Criminal Tax Penalties Committee of the American Bar Association’s Section of Taxation. Caroline has also served as an instructor with the IRS Military Volunteer Income Tax Assistance program at Ft. George G. Meade in Maryland.

She has been recognized by Chambers (Tax Fraud (Nationwide), Tax (DC)), Benchmark, Best Lawyers in America (Litigation and Controversy – Tax, Tax Law), Super Lawyers (Top 10 Attorneys in Maryland, Maryland cover story in 2013, DC), Euromoney Legal Media Group’s Americas Women in Business Law Awards (Best in Tax Dispute Resolution) (2014), and The Daily Record’s Top 100 Women Circle of Excellence. Caroline is a recipient of the ABA Section of Taxation’s Janet Spragens Pro Bono Award, and in January 2017, she was recognized by IRS Chief Counsel William Wilkins with the Chief Counsel Award, the highest honor that can be conferred by that office.

Caroline is an Adjunct Professor at the Georgetown University Law Center (International Tax Controversies, Criminal Tax Law and Procedure) and University of Baltimore School of Law Graduate Tax Program (Investigation, Prosecution and Defense of Tax Crimes).

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