Professionals: Tax Compliance and Abuse

COMPLIANCE, AVOIDANCE, AND EVASION IN TAXATION:
THE ROLE OF PROFESSIONALS

This series of three international roundtables aims at exploring in an innovative way the key role played by professionals in the area of taxation. The events will be structured so to focus on three areas in which professionals can be placed based on the ethics and legality of their behaviors:

the “bright” area, characterized by ethical and lawful conduct;
the “gray” area, featured by unethical behavior at the crossroads of legality and illegality;
the “dark” area, characterized by unethical and criminal conduct.

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The events will aim at offering an overview of these three forms of professional conduct, exploring their main features, and discussing the most relevant and critical issues from a multidisciplinary perspective. In order to achieve such an objective, the research events will adopt an integrated phenomenological, ethical, and legal perspective.

This roundtable series is co-organized by Prof. Diane Ring, who serves as a Professor in Law at Boston College Law School, Dr. Costantino Grasso, who serves as an Associate Professor of Law at Manchester Law School, and Dr. Donato Vozza, who serves as a Lecturer in Law at the University of Roehampton.

THE BRIGHT AREA

The first roundtable entitled “Compliance, Avoidance, and Evasion in Taxation: The Role of Professionals - The Bright Area“ will be held on Zoom on the 3rd of February 2023 from 2:30 pm GMT (10:00 am EST). During the roundtable, several terrific panelists will explore the key role played by professionals in the area of tax compliance with a special emphasis on ethical approaches and adherence to the rule of law. The video recordings of the event are available below.

Moderator: Diane Ring

Diane is a Professor of Law and the Dr. Thomas F. Carney Distinguished Scholar at Boston College Law. She researches and writes primarily in the field of international taxation, corporate taxation, and ethical issues in tax practice. Her recent work addresses issues including information exchange, tax leaks, international tax relations, sharing economy and human equity transactions, and ethics in international tax. Diane was a consultant for the United Nation’s 2014 project on tax base protection for developing countries, and the U.N.'s 2013 project on treaty administration for developing countries.

Robert Attard

Robert is EY Malta's Tax Leader and Visiting Senior Lecturer at the University of Malta. From 2015 to 2017, he was the IBFD General Rapporteur on the Protection of Taxpayers’ Rights. Robert assists taxpayers in constitutional cases in Malta and he submitted arguments to the ECtHR Grand Chamber in the case Lekic v. Slovenia. He is a member of the Supervisory Council of the Observatory for Taxpayers’ Rights. Robert has published widely in the area of taxation and his most recent publication is Taxation at the European Court of Human Rights co-authored with former ECtHR judge Pinto de Albuquerque (Wolters Kluwer Law 2023).

Scott Cummings

Scott is Robert Henigson Professor of Legal Ethics and Professor of Law, at UCLA School of Law. He teaches and writes about the legal profession, legal ethics, access to justice, and local government law. Scott is also the founding faculty director of the UCLA Program on Legal Ethics and the Profession. In 2021, he was selected as the Fulbright Distinguished Chair at the European University Institute and a fellow at the Stanford Center for the Advanced Study in the Behavioral Sciences to study the role of lawyers in strengthening the rule of law.

Elaine Doyle

Elaine is a Professor of Taxation at the University of Limerick, Ireland. She qualified as a Chartered Accountant and a Chartered Tax Advisor, working in PwC Dublin and EY Limerick before moving into academia. She has been awarded numerous accolades for excellence in higher-level teaching and learning and has undertaken several leadership roles in academia, locally and nationally. Her research focuses on professional ethics and risk management in tax practice, tax compliance, ethical reasoning and ethics education.

Samantha Feinstein

Samantha is a Staff Attorney and Director of the International Program at the Government Accountability Project. She develops and advances private sector whistleblower-rights legislation; represents public, private, and international whistleblower clients; and conducts research, training, advocacy, and public education for the international program. Ms. Feinstein is co-author of the Government Accountability Project and International Bar Association joint report "Are Whistleblower Laws Working? A Global Study of Whistleblower Protection Litigation," published in March 2021.

María Amparo Grau Ruiz

María Amparo is Full Professor of Tax Law at the Complutense University of Madrid, and Visiting Professor of Transnational Taxation at Northwestern University. She is also Director of the Research Group “Law for Sustainable Development: socially responsible tax, labor and administrative measures,” and Principal Investigator of the AudIT-S project, on "Legal and financial significance of sustainability audit schemes through smart data management”, funded by the Spanish Ministry of Science and Innovation. Member of the Spanish Royal Academy of Jurisprudence and Legislation.

Henry Grzes

Henry is currently a Lead Manager on the Tax Practice & Ethics team of the AICPA possessing over forty years of experience in the profession. In his career, he has held positions of tax leadership in several regional, national, and international firms, addressing domestic and international compliance and planning issues. His current responsibilities at the AICPA include acting as the staff liaison to the AICPA’s Tax Practice Responsibilities Committee, the Statements on Standards for Tax Services (SSTSs) Revision Task Force and the Circular 230 Revision Task Force.

Mary Inman

Mary is a partner in Constantine Cannon’s London and San Francisco offices, and the head of the firm’s International Whistleblower practice. She specializes in representing whistleblowers worldwide under the US whistleblower reward program. Her successful efforts to export the US whistleblower programs to the UK were featured in the New York Times. Mary represents renowned SEC whistleblower Tyler Shultz who exposed the infamous Silicon Valley blood-testing start-up Theranos. She is a regular commentator on whistleblower matters for the Financial Times, BBC, New York Times, Wall Street Journal, and Reuters.

Nina Olson

Nina is the Executive Director of the Center for Taxpayer Rights, a nonprofit that works to advance taxpayer rights in the United States and internationally. From March 2001 to July 2019, Nina served as the National Taxpayer Advocate, leading the Taxpayer Advocate Service, an independent organization within the Internal Revenue Service (IRS) dedicated to assisting taxpayers to resolve their problems and making administrative and legislative recommendations aimed at mitigating those problems. Formerly, Nina founded and directed The Community Tax Law Project, and maintained a private legal practice.

Daniel Ostas

Daniel holds the James G. Harlow, Jr. Chair in Business Ethics at the University of Oklahoma. He has taught business economics, business law, and business ethics at both the undergraduate and graduate levels, and has received more than twenty teaching awards. His research addresses the economics of marketplace ethics and the ethics of corporate legal strategy. An author of more than seventy scholarly works, including three books, Ostas has received more than a dozen international research awards. His co-authored book, Corporate Taxation and Social Responsibility was recently published by Wolters Kluwer International.

Jens Poll

Jens serves as Non-Executive Director and Audit Committee Chair in several medium-sized companies with global activities. He works as an expert, expert witness, and arbitrator in international arbitration proceedings. He also teaches law and regulation at the University of Ulm and is, inter alia, Chair of the Commission on Quality Assurance at WPK (Wirtschaftsprüferkammer). He is a member of the International Ethics Standards Board for Accountants (IESBA) since January 2018 and is chairing the Tax Planning and Related Services Task Force. Since December he is Deputy-President of Accountancy Europe.

Carlos Weffe

Carlos was a former Senior Research Associate and Scientific Coordinator of the Observatory for the Protection of Taxpayers' Rights, International Bureau of Fiscal Documentation (IBFD). Associate Professor and former Chair of "Public Finance", Universidad Central de Venezuela. Professor of "Taxation and Human Rights", Universidad Monteávila. A representative for Panama to the Board of Directors of the Latin American Institute of Tax Law (ILADT), a member of the Panamanian Association of Financial and Tax Law (APADEFT). He also serves as the Head of Area - Tax Abuse of the Corporate Crime Observatory.

VIDEO RECORDINGS

Suggested Citation

BLUEBOOK: [Name Surname], ‘Compliance, Avoidance, and Evasion in Taxation: The Role of Professionals - The Bright Area,’ CORPORATE CRIME OBSERVATORY, [Opening Session/Session 1/Session 2/Session 3] at [00:00] (Feb. 3, 2023), www.corporatecrime.co.uk/professionals-tax-compliance-and-abuse

APA: [Surname, Initial] (2023, Feb. 3). ‘Compliance, Avoidance, and Evasion in Taxation: The Role of Professionals - The Bright Area’. Corporate Crime Observatory. Video recording [Opening Session/Session 1/Session 2/Session 3] at [00:00]. Retrieved from www.corporatecrime.co.uk/professionals-tax-compliance-and-abuse

HARVARD: [Surname, Initial] (2023) ‘Compliance, Avoidance, and Evasion in Taxation: The Role of Professionals - The Bright Area’. Corporate Crime Observatory. Video recording [Opening Session/Session 1/Session 2/Session 3] at [00:00]. Available at: www.corporatecrime.co.uk/professionals-tax-compliance-and-abuse

OSCOLA: [Name Surname], ‘Compliance, Avoidance, and Evasion in Taxation: The Role of Professionals - The Bright Area’, (Corporate Crime Observatory, 3 February 2023), video recording [Opening Session/Session 1/Session 2/Session 3] at [00:00] <www.corporatecrime.co.uk/professionals-tax-compliance-and-abuse>

The international roundtable commenced with opening remarks delivered by Dr. Costantino Grasso, who serves as an Associate Professor of Business and Law at Manchester Law School, followed by an introduction offered by Prof. Diane Ring, who serves as a Professor of Law at Boston College Law, and a case study presented by Prof. Jens Poll, who teaches law and regulation at the University of Ulm.

Opening Session
The new sections of the IESBA’s Tax Planning and Related Services - Exposure Draft

Subsequently, the discussion was divided into the three following thematic sub-sessions.

Session 1 - 02:40-4:00 pm GMT (09:40-11:00 am EST)
The Relationship Between Tax Professions, the State, Taxpayers, and Society - How Professionals are Regulated

This first session will explore the characteristics of the relationship between tax professionals and the state (e.g., prevention of tax authorities’ mistakes, safeguarding individuals from potential abuses in the administration of taxation), the characteristics of the relationship between tax professionals and taxpayers (e.g., prevention of taxpayers’ mistakes, how can tax professionals enhance tax compliance and taxpayers’ behavior), as well as the characteristics of the relationship between tax professionals and society (e.g., how could tax professionals foster equality, fairness, and justice of the taxation system). This session will also focus on the applicable legal frameworks by exploring issues like the features and main functions of tax professionals’ regulators, how the legal framework in the area of taxation affects the role of tax professionals, and how can legislation foster tax compliance or assist in unveiling tax misconduct.

Session 2 - 4:15-5:45 pm GMT (11:15 am -12:45 pm EST)
Tax Professionals: Their Ethics and Their Role in Enforcement

The second session will focus on the most relevant aspects of professional ethics and the fundamental values that should guide tax professionals’ activities. It will explore the tensions between loyalty towards clients, the State, and society and how
they could be managed in compliance with the rule of law as well as other fundamental values. It will discuss if tax professionals should have a moralizing role. It will investigate what is the role of tax professionals in unveiling tax misconduct and other related illegal activities such as money laundering and corrupt practices, and explore in which way tax professionals may be involved in disclosing illegal or unethical forms of conduct.

Session 3 - 6:00-7:30 pm GMT (1:00-2:30 pm EST)
Tax Professionals: Globalization & Capitalism

The third session will explore the main characteristics of the modern, entrepreneurial, market-oriented logic of professional services and how they affect the role of tax professionals. It will investigate how the structure and dimension of big law or accounting firms affect the activities of tax professionals. It will also focus on the problematic aspects related to potential conflicts of interest in tax professionals’ practice (e.g., external auditing services and tax consultations, internal audit, and client representation) as well as the best practices to avoid them. Finally, it will discuss if it would be possible to imagine a world with robot-tax professionals.

THE GRAY AREA
PART I
AT THE CROSSROADS OF TAX PRACTICES:

ETHICAL CHALLENGES AND DEMOCRATIC ISSUES

The aim of this international roundtable is to engage in a comprehensive examination of the ambiguous domain known as the "gray area" in taxation, a realm where taxpayers' actions oscillate between legality and illegality. The discussion will delve into how tax professionals facilitate various forms of tax abuse, such as aggressive tax strategies and the creation of shell entities while operating in this nebulous zone. A significant focus will be placed on the ethical dimensions and varying loyalties of tax professionals, scrutinizing how their allegiance to clients can sometimes conflict with their responsibilities to the state and society at large, thereby posing risks to democratic values and the rule of law. Furthermore, the event will explore the organizational structures and profit motives that shape the tax profession, questioning the ethical underpinnings and conflicts of interest inherent in the industry. Lastly, the roundtable will address educational and ethical responsibilities in the fields of law, business, and taxation.

This event, which represented the first part of the session entitled “Compliance, Avoidance, and Evasion in Taxation: The Role of Professionals - The Gray Area“ was held on Zoom on the 8th of September 2023 from 3:30 pm BST (10:30 am EDT).

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Moderator: Diane Ring

John Christensen

Trained as a forensic auditor and as an applied economist, John has conducted several major international fraud investigations and spent many years working in offshore finance, including a period of employment with Big 4 accounting firm Deloitte. From 1987 to 1998, he headed the government economic service of the British Channel Island of Jersey. He is a co-founder and former Chair of the Board of the global Tax Justice Network. He is also a founder and a member of the Governance Board of Tax Inspectors Without Borders, an OECD/UNDP initiative.

Fabio de Sa and Silva
Fabio is an Associate Professor of International Studies and Wick Cary Professor of Brazilian Studies, University of Oklahoma. A sociolegal scholar, Fabio developed award-winning studies of the anticorruption crusade lava jato and the crisis of Brazilian democracy. Currently, he is one of the coordinators of the Project on Autocratic Legalism (PAL), an international research network that promotes studies on law and democratic backsliding, and the host of PAL’s Podcast (PALcast).

Philip Laroma Jezzi

Philip is an Associate Professor of Tax Law at the University of Florence, Italy. In 2009 he received his Master of Arts in Tax at the Institute of Advanced Legal Studies (IALS) in London, UK. His research and study focus on the tax liability of trusts and other non-corporate entities and European - International Tax Law. His academic career attracted media coverage after he exposed the systemic corruption at the root of the Italian academic recruiting system.

Linda Lee

Linda is a senior solicitor at Weightmans, specializing in regulatory law. She is the current Chair of the Law Society's Professional Indemnity Committee and a former President. Linda serves as a Commissioner for the Criminal Cases Review Commission and works as a Deputy District Judge and assistant Coroner. She chairs legal panels for the General Medical Council and the NHSLA's Primary Care Appeals Service. Additionally, she is involved in various other committees and frequently lectures on regulatory issues.

Charles Middleton

Charles is an international tax attorney, holding an LLM in Tax Law from New York University and a JD from the University of Alabama. His illustrious career has spanned various positions at multiple corporate behemoths. He has formerly served as a tax officer at General Electric, Caterpillar, Walmart, and Oxbow, leading Walmart's global tax planning initiatives. Charles also directed the tax departments at Financial Guarantee Insurance Corp and GE Asset Management, where he managed a portfolio exceeding $200 billion in assets. Acting as a whistleblower, he exposed significant corporate tax malpractices.

Richard Murphy

Richard is a Professor of Accounting Practice at Sheffield University Management School. He is a Fellow of the Institute of Chartered Accountants in England and Wales. He co-founded the Tax Justice Network, the Fair Tax Mark, and Finance for the Future. He founded and still directs Tax Research UK. He co-created the Green New Deal. He is the founder-director of the Corporate Accountability Network. He developed the concept of country-by-country reporting and authored a number of books including The Courageous State and The Joy of Tax. He is a frequent commentator in the media on tax and accounting issues.

Dan Neidle

Dan worked as a tax lawyer for many years, advising financial institutions, corporations, governments, and others on UK and international tax law and tax policy. He retired from his role as head of tax at Clifford Chance in 2022, and founded Tax Policy Associates. Dan is now applying his experience and specialized knowledge to enhance tax policy, as well as influence and inform discussions surrounding taxation. He was recognized by The Lawyer as one of the UK's 100 most impactful legal professionals and his endeavors were honored with the Tolley's 2023 award for "Exceptional Contribution to Taxation in 2022-23."

Jason Piper

Jason is Head of Tax and Business Law in the Professional Insights team at ACCA, the global body for professional accountants, leading policy work on the two closely related fields. His research covers all aspects of business form and their regulation, how they interact with tax systems and the wider economic and social environment, including the influence of technological change on the regulatory and economic environments for entrepreneurs and criminals. Jason represents ACCA on tax, business law and economic crime issues at the UK, regional, and international levels.

Siddhesh Rao

Siddhesh is a PhD researcher at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business). His research focuses on policy issues of money laundering, illicit financial flows, taxes, and good governance. Previously, Rao worked in a private tax practice in India advising multinational enterprises and corporations. He is a member of the Institute of Chartered Accountants of India and holds an LLM in international tax law from WU.

Samar Riaz

Samar is a management professional with backgrounds in technology, management, and education. He holds an MBA from the UK, an MA from Sweden, and a PhD in Business and Management from Austria. His doctoral thesis examined the hegemonic role of traditional accounting and the role of counter-accounts in challenging that hegemony. Samar teaches at a business school in Germany, coaches leaders, and provides consulting services focusing on organizational behavior. His podcast "Counter Accounts" covers diverse perspectives on contemporary socioeconomic issues.

Theodore Seto

Theodore is the Frederick J. Lower, Jr. Chair and Professor of Law at LMU Loyola Law School, Los Angeles. After graduating from Harvard College and Harvard Law School and clerking on the Second Circuit, he practiced at Foley, Hoag, & Eliot in Boston and Drinker Biddle & Reath in Philadelphia, where he became a partner in the tax department. He joined the faculty at Loyola in 1991 and currently teaches tax, property law, and public finance.

Martiana Sipahutar

Martiana works for the Indonesian tax authority. She is a certified tax investigator and has specialized in tax law enforcement and related money laundering for more than 15 years. She is an Indonesian delegate for the Working Group on Exchange of Information in the OECD's Taskforce on Tax Crimes and Other Crimes (TFTC) and is in charge of other forms of international cooperation (R.40) for Indonesia's Mutual Evaluation Review of FATF. She also serves as an Assistant Editor of the Corporate Crime Observatory.

Paul D. Scott

Paul served as a trial attorney in the Civil Fraud Section at the U.S. Department of Justice. Since leaving the Department of Justice, he has maintained a nationwide whistleblower practice, pursuing a wide variety of claims under the U.S. False Claims Act, the IRS, SEC, and Anti-Money Laundering whistleblower programs, and various international whistleblower programs. Paul currently serves as a board member for The Anti-Fraud Coalition, the largest whistleblower organization for lawyers in the United States. Paul’s firm represented the whistleblower in the successful action against Lance Armstrong in connection with the doping scandal involving the U.S. Postal Service sponsored cycling team.

Robert F. van Brederode

Robert (LLB, LLM, PhD) is a tax lawyer and scholar with over 35 years of experience in international tax. He held leadership positions in tax with several of the Big 4 accounting firms and served as a professor of Tax Law at the Erasmus University in the Netherlands, and as an adjunct professor at New York University, School of Law, Graduate Tax Program. Currently, he is associated as a University Professor with the Global Humanistic University in Curaçao. Dr. van Brederode is the author of dozens of academic journal articles and the author or editor of 11 books.

Carlos Weffe

VIDEO RECORDINGS

Suggested Citation

BLUEBOOK: [Name Surname], ‘Compliance, Avoidance, and Evasion in Taxation: The Role of Professionals - The Gray Area; Part 1 - At the Crossroads of Tax Practices: Ethical Challenges and Democratic Issues’ CORPORATE CRIME OBSERVATORY, [Thematic Area (1)/Thematic Area (2)/Thematic Areas (3/4)] at [00:00] (Sept. 8, 2023), www.corporatecrime.co.uk/professionals-tax-compliance-and-abuse

APA: [Surname, Initial] (2023, Sept. 8). ‘Compliance, Avoidance, and Evasion in Taxation: The Role of Professionals - The Gray Area; Part 1 - At the Crossroads of Tax Practices: Ethical Challenges and Democratic Issue’. Corporate Crime Observatory. Video recording [Thematic Area (1)/Thematic Area (2)/Thematic Areas (3/4)] at [00:00]. Retrieved from www.corporatecrime.co.uk/professionals-tax-compliance-and-abuse

HARVARD: [Surname, Initial] (2023) ‘Compliance, Avoidance, and Evasion in Taxation: The Role of Professionals - The Gray Area; Part 1 - At the Crossroads of Tax Practices: Ethical Challenges and Democratic Issue’. Corporate Crime Observatory. Video recording [Thematic Area (1)/Thematic Area (2)/Thematic Areas (3/4)] at [00:00]. Available at: www.corporatecrime.co.uk/professionals-tax-compliance-and-abuse

OSCOLA: [Name Surname], ‘Compliance, Avoidance, and Evasion in Taxation: The Role of Professionals - The Gray Area; Part 1 - At the Crossroads of Tax Practices: Ethical Challenges and Democratic Issue’, (Corporate Crime Observatory, 8 September 2023), video recording [Thematic Area (1)/Thematic Area (2)/Thematic Areas (3/4)] at [00:00] <www.corporatecrime.co.uk/professionals-tax-compliance-and-abuse>

Compliance, Avoidance, and Evasion in Taxation: The Role of Professionals - The Gray Area
Part 1 - At the Crossroads of Tax Practices: Ethical Challenges and Democratic Issues
Thematic Area (1): Into the Gray, Exploring the Boundaries of Tax Advisers' Professional Activities

This part of the discussion focuses on the gray area of tax professionals, where tax abusive practices thrive between legal and illegal tax practices. It analyzes the characteristics of these actions, highlights the involvement of professionals such as accountants, lawyers, and other figures, and addresses the manipulation of legislation and the complexity of the tax system. Furthermore, it emphasizes the privileged position of tax professionals, ethical distinctions, varying perceptions of complexity, concerns within the tax industry, and the collaboration of diverse professionals in facilitating tax abuses within this gray area.

Compliance, Avoidance, and Evasion in Taxation: The Role of Professionals - The Gray Area
Part 1 - At the Crossroads of Tax Practices: Ethical Challenges and Democratic Issues
Thematic Area (2): Investigating the Drivers of Professional Behavior within the “Gray” Area

This section investigates the tensions between loyalty to clients, and loyalty to the State and society within the context of taxation. It aims to examine how various forms of loyalty can clash with the rule of law and fundamental values, particularly in cases of state capture. It focuses on the implications of exploiting tax laws for "tax abuses" and the resulting impact on democratic societies. Additionally, it investigates the connections between unethical professional practices and assault on democratic values.

Compliance, Avoidance, and Evasion in Taxation: The Role of Professionals - The Gray Area
Part 1 - At the Crossroads of Tax Practices: Ethical Challenges and Democratic Issues
Thematic Areas (3/4): Alignment and Misalignment with Democratic Values; Education and Professional Training

This part of the discussion explores the tensions between loyalty to clients, and loyalty to the State and society within the context of taxation. It aims to examine how various forms of loyalty can clash with the rule of law and fundamental values, particularly in cases of state capture. It focused on the implications of exploiting tax laws for "tax abuses" and the resulting impact on democratic societies. Moreover, the debate focuses on various aspects related to education, professional training, and ethical responsibility in the fields of law, business, and taxation.

THE GRAY AREA
PART II
THE CONUNDRUMS OF TAX PROFESSIONALS:

TECHNOLOGY, WHISTLEBLOWING, AND ETHICAL DECISION-MAKING

This event, which represents the second part of the session entitled “Compliance, Avoidance, and Evasion in Taxation: The Role of Professionals - The Gray Area“ was held on Zoom on the 11th of October 2023 from 3:00 pm BST (10:00 am EDT).

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Moderator: Diane Ring

Paul Aplin

Paul spent 40 years in general practice advising SME’s and individuals on tax. He is a past president of ICAEW, sits on the ICAEW Tax Faculty Board, CIOT Council, CFE Technology Committee, HMRC’s Administrative Burdens Advisory Board and the HMRC GAAR Panel. He advises a number of technology and software businesses. Since filing the UK’s first electronic personal tax return in 1997 he has taken a deep interest in the impact of technology on tax administration and writes and speaks extensively on the topic.

Filippa Marullo Anzalone

Filippa is a Professor of Law and the Associate Dean for Library & Technology Services at Boston College Law School. She is both a certified MBSR (Mindfulness-Based Stress Reduction) and MIEA (Mindfulness Institute for Emerging Adults) instructor. She teaches a course at BC Law called Mindfulness and Contemplative Practices for Lawyers that encourages students to develop sustainable coping methods for lifelong health and success in the legal profession.

Meredith Barges

Meredith is a Policy Analyst and Interfaith Chaplain working in the areas of ethics, advocacy, and social change. She has worked at Yale Law School, the International Center for Transitional Justice, and the International Human Rights Law Institute. She earned a Master of Divinity degree from Yale Divinity School, a certificate from Andover Newton Seminary, and a Master of Arts in cultural theory from the University of Chicago.

Dawn Carpenter

Dawn is a veteran of Wall Street with the heart of a teacher and a scholar. Her groundbreaking research in contributive justice theory offers an ethical frame for understanding the social and moral value of economic life. She is the host and executive producer of the What Does It Profit podcast and is the author of the forthcoming book-- What We Owe Each Other: Contributive Justice and Our Relationship with Work and Wealth.

Samantha Feinstein

Samantha is a Staff Attorney and Director of the International Program at the Government Accountability Project, a nonprofit organization dedicated to protecting whistleblowers and promoting government and corporate accountability. With over 22 years of experience, she is a leading expert in whistleblower law, anticorruption, human rights, and good governance. Samantha is also is also Vice Chair of the Board of the UN Convention Against Corruption Coalition.

Paul E. Fiorelli

Paul worked as a Tax Attorney at Ernst & Whinney (now EY) for two years. After this, he became a tenured, Full Professor at Xavier University, and now Directs the Cintas Institute for Business Ethics. He has received numerous teaching awards, including the 2022-2023 MBA Professor of the Year. He was a Supreme Court Fellow, working at the U.S. Sentencing Commission, and he actively consults on ethics. His book, “Establishing Workplace Integrity: Six Lessons in Values-based Leadership” should be published in 2024.

Susan S. Fortney

Susan serves as a University Professor at Texas A&M University School of Law where she directs the Program for the Advancement of Legal Ethics. Her research focuses on issues related to legal ethics and malpractice, as well as organizational ethics. She currently serves as the Principal Investigator on a National Science Foundation project that involves developing a self-assessment tool designed to enable universities and colleges to examine and improve how they address sexual harassment in STEM.

María Amparo Grau Ruiz

María Amparo is a Professor of Tax Law at the Complutense University of Madrid, and Visiting Professor of Transnational Taxation at Northwestern University. She is also Director of the Research Group “Law for Sustainable Development: socially responsible tax, labor and administrative measures,” and Principal Investigator of the AudIT-S project, on "Legal and financial significance of sustainability audit schemes through smart data management”, funded by the Spanish Ministry of Science and Innovation.

Mary Inman

Daniele Majorana

With over 25 years of experience, Daniele is an expert in international and EU tax consulting, specializing in sectors like banking and energy. He has served as a tax manager at SNAM and is an independent director supervised by the Bank of Italy. Daniele has published over 30 articles on EU tax reforms and the digital economy and is a recognized speaker at tax conferences. He holds multiple professional affiliations and academic roles, including being a registered Chartered Accountant in Milan and the UK.

Omri Marian

Omri is a Professor of Law at the University of California, Irvine (UCI) School of Law, where he was also the founding Academic Director of the Graduate Tax Program. Before joining UCI, he was an assistant Professor of Law at the University of Florida where he taught in the graduate tax program. He also practiced as a tax associate in the New York office of Sullivan & Cromwell LLP. Professor Marian writes in the areas of international and comparative taxation, and tax and technology.

David Morgan

David is a consultant psychotherapist and psychoanalyst in both the NHS and private practice, formerly at the Portman Clinic. He is a Fellow of the British Psychoanalytic Society and serves as a training analyst and supervisor. Morgan specializes in working with marginalized groups such as migrants, whistleblowers, and socio-political organizations, offering psychological reports for asylum seekers. His publications cover topics like violence, perversion, and delinquency, as well as narcissism, love, and death.

Eli Moskowitz

Eli Moskowitz is an investigative journalist at the Organized Crime and Corruption Reporting Project (OCCRP), where he focuses on how financial secrecy and tax havens are linked to environmental crime and corruption. His investigations draw on large troves of leaked data, along with insights from well-placed industry sources and whistleblowers. Prior to working at OCCRP, Eli studied at Universitat Pompeu Fabra in Barcelona, where he wrote his dissertation on OECD tax policy.

James Quarmby

Recently recognized as "tax & trusts lawyer of the year," James is the head of Stephenson Harwood LLP private wealth team. James is widely regarded as one of the leading practitioners in advising clients on UK and international taxation. He writes and lectures widely on tax policy, and frequently appears in the press and broadcast media. As well as being a solicitor, he is a Registered Tax Technician, and an active member of STEP and a contributing editor for Lexis/Nexis.

Siddhesh Rao

Michael J. Ronickher

Michael Ronickher is a partner in the Washington, DC, office of Constantine Cannon LLP. He represents a broad range of whistleblowers, including in financial fraud, healthcare, and defense cases. Mr. Ronickher also draws on long experience in the U.S. Department of Justice, Tax Division, to represent numerous individuals who have exposed illegal tax avoidance through the U.S. IRS’s whistleblower program.

Christopher Sykes

Chris is a Senior Lecturer and Programme Lead for the LLM Legal Practice at Manchester Law School. He was a criminal defense solicitor, primarily practicing in the area of ‘white collar’ crime. He then worked as a teacher of legal skills and law in Spain, before co-founding Hong Kong-based legal tech business Zegal. He has since worked as a Lecturer at BPP Law School. His main area of interest is legal technology.

Marie Terracol

Marie is the Whistleblower Protection Lead at Transparency International, a global movement working in over 100 countries to end the injustice of corruption. She leads their policy and advocacy efforts to improve the protection of whistleblowers in Europe and across the globe, so they can safely speak up about corruption and other wrongdoing. She is the author of several publications on the topic, the most recent being Internal Whistleblowing Systems – Best Practice Principles for Public and Private Organisations (2022).

Wouter van Gelderen

Wouter has been a lifelong consultant in finance, tax, and technology. He has worked for several of the Big Four audit firms as well as two listed consulting companies. His drive to improve finance globally has led him to serve more than 30 CFOs of Fortune 500 companies in approximately 40 countries over a span of 27 years as a consultant. During this time, he has executed numerous offshoring projects driven by tax and labor cost differences. However, he is particularly passionate about the practical applications of disruptive technologies such as blockchain, robotics, and artificial intelligence.

Carla Vijian

Carla is a Chartered Accountant with over 20 years of experience, who serves as a Principal at the International Ethics Standards Board for Accountants (IESBA) where she leads the Tax Planning and Related Services project and other initiatives. Previously, she worked in the audit practice of Deloitte London and Sydney, where she managed transnational audits, specializing in all aspects of financial reporting, internal controls assurance, and financial and non-financial performance information.

VIDEO RECORDINGS

Suggested Citation

BLUEBOOK: [Name Surname], ‘Compliance, Avoidance, and Evasion in Taxation: The Role of Professionals - The Gray Area; Part 2 - The Conundrums of Tax Professionals: Technology, Whistleblowing, and Ethical Decision-Making’ CORPORATE CRIME OBSERVATORY, [Opening Remarks/Case Study/Thematic Area (1)/Thematic Area (2)/Thematic Area (3)] at [00:00] (Oct. 11, 2023), www.corporatecrime.co.uk/professionals-tax-compliance-and-abuse

APA: [Surname, Initial] (2023, Oct. 11). ‘Compliance, Avoidance, and Evasion in Taxation: The Role of Professionals - The Gray Area; Part 2 - The Conundrums of Tax Professionals: Technology, Whistleblowing, and Ethical Decision-Making’. Corporate Crime Observatory. Video recording [Opening Remarks/Case Study/Thematic Area (1)/Thematic Area (2)/Thematic Area (3)] at [00:00]. Retrieved from www.corporatecrime.co.uk/professionals-tax-compliance-and-abuse

HARVARD: [Surname, Initial] (2023) ‘Compliance, Avoidance, and Evasion in Taxation: The Role of Professionals - The Gray Area; Part 2 - The Conundrums of Tax Professionals: Technology, Whistleblowing, and Ethical Decision-Making’. Corporate Crime Observatory. Video recording [Opening Remarks/Case Study/Thematic Area (1)/Thematic Area (2)/Thematic Area (3)] at [00:00]. Available at: www.corporatecrime.co.uk/professionals-tax-compliance-and-abuse

OSCOLA: [Name Surname], ‘Compliance, Avoidance, and Evasion in Taxation: The Role of Professionals - The Gray Area; Part 2 - The Conundrums of Tax Professionals: Technology, Whistleblowing, and Ethical Decision-Making’, (Corporate Crime Observatory, 11 October 2023), video recording [Opening Remarks/Case Study/Thematic Area (1)/Thematic Area (2)/Thematic Area (3)] at [00:00] <www.corporatecrime.co.uk/professionals-tax-compliance-and-abuse>

Compliance, Avoidance, and Evasion in Taxation: The Role of Professionals - The Gray Area
Part 2 - The Conundrums of Tax Professionals: Technology, Whistleblowing, and Ethical Decision-Making
Case Study - Innovation and AI in Corporate Taxation: A Story of Organizational Resistance, Ethical and Governance Issues
(Wouter Van Gelderen)

This section delves into the lack of transparency surrounding tax professionals’ practices. It highlights the impact of notable leaks like the Panama Papers in uncovering instances of tax abuse. The analysis also considers the ethical dilemma faced by tax professionals in reporting illegal activities and the broader implications of exposing ethically questionable practices. Factors contributing to the determination of public interest in uncovering tax abuse are examined, along with the role of transparent beneficial owner registers in preventing malpractice.

This section explores the role of technology and digital innovation within the realm of gray area taxation. It investigates how advancements in technology shape the roles, responsibilities, and practices of tax professionals. It delves into the influence of artificial intelligence on gray area tax operations examining the potential for tax professionals to leverage innovations like AI and machine learning to navigate and exploit gray areas while considering ethical considerations and implications for accountability.

Compliance, Avoidance, and Evasion in Taxation: The Role of Professionals - The Gray Area
Part 2 - The Conundrums of Tax Professionals: Technology, Whistleblowing, and Ethical Decision-Making
Thematic Area (3): Moral Distress and Tax Professionals

Moral distress refers to a psychological and emotional state that arises when individuals face situations where their personal values, ethical principles, or moral beliefs are challenged or compromised. It occurs when individuals are aware of the morally right course of action but face constraints that prevent them from acting accordingly because they find themselves in circumstances that require them to make decisions or take actions that conflict with their deeply held moral convictions. Moral distress can emerge in various contexts, including professional environments.

THE DARK AREA

The third roundtable is entitled “Compliance, Avoidance, and Evasion in Taxation: The Role of Professionals - The Dark Area“. This event is organized with the cooperation of the Italian Judicial College (Scuola Superiore della Magistratura – Sede Decentrata di Napoli).

The main goal of this International Roundtable is to examine professionals’ unethical and criminal forms of behavior in the field of taxation. The experts will investigate a range of issues related to tax fraud and evasion, focusing not just on the fundamental methods employed by professionals or their firms to facilitate these practices, but also examining their role in a broader criminal context characterized by the intersection of tax crimes with other illicit activities such as money laundering, corruption, and organized crime. The session will discuss the approaches used to hold tax practitioners accountable, including criminalization, investigative techniques, and other enforcement strategies. Finally, the session will focus on the crucial role that the enhancement of transparency measures and the protection of whistleblowers may have in countering such phenomena. By doing so, the event aims to offer a comprehensive perspective on the negative impact criminal involvement of professionals has on the taxation system and to propose potential strategies for fostering professional accountability.

CCO Tax Front Sess 3 Eras Bold ITC 35-30 dark area.jpg

This event will be held on Zoom on the 10th of November 2023 from 3:00 pm BST (10:00 am EDT).

Join for free on Zoom for what is expected to be a fascinating discussion by registering at the following link:

https://mmu-ac-uk.zoom.us/webinar/register/WN_gh7p314wSb-mwG0eG_gCmg

Moderator: Diane Ring

Tea Budinski

Tea serves as a Deputy Municipal State Attorney in Zagreb, having initially begun her legal career in law offices focused on civil matters including labor, economic, and business law. Since 2019, she has been working at the State Attorney's Office. Since 2021, she has been focusing on international legal assistance and judicial cooperation in criminal cases. Her responsibilities include executing European investigation orders and arrest warrants, as well as property confiscation in international cases concerning tax evasion, money laundering, and drug-related crimes.

Henrique de Sá Valadão Lopes

Henrique is a Federal Prosecutor at the Federal Prosecution Office (MPF) of Brazil. Since 2021, he has been the Coordinator of the National Support Team for Money Laundering, Financial Investigations, Tax and Financial Crimes (GALD-CFIF-SFN) at MPF. Between 2019 and 2020, he worked as the Coordinator for the Working Group for Tax Crimes at MPF. Between 2013 and 2016, he was a Treasury Attorney and worked with Civil Fraud at the National Treasury Attorney’s Office.

Rudolf Elmer

Rudolf worked for various financial institutions, including Bank Julius Baer, Credit Suisse, KPMG, Noble Group in Zurich and in Cayman for Julius Baer Bank, Standard Bank of Africa in Mauritius as well as in Jersey, UK. Throughout his career, Rudolf served as a Chief Operating Officer, Compliance Officer, Currency Trader, Hedge Fund and Private Equity Manager, and auditor. In addition to his financial expertise, Rudolf also held the position of captain in the Swiss Army. His experience as a whistleblower has been featured in the documentary Offshore - Elmer and the Swiss Bank Secrecy by Werner Schweizer.

Calogero Ferrara

Calogero has been working as a European Delegated Prosecutor at the European Public Prosecutor Office since May 2021. Prior to that, he was a Deputy Prosecutor in Palermo for 21 years, involved in multiple specialized units including antiterrorism and anti-mafia. Calogero also served as a Trial Attorney at the International Criminal Tribunal for the former Yugoslavia between 2007 and 2009. He has extensive experience as a speaker in training and seminars for judges, prosecutors, jurists, and law enforcement officers in Italy and abroad.

Ahsan Habib

Ahsan works in Canada as a Senior Analyst in AML Operations Governance. He is an experienced banker from Bangladesh where he worked in Correspondent Banking and Trade Finance in top-ranked banks. He was recognized as ACAMS AFC Professional of the Year 2021. He is also a Member of the Advisory Board of the Financial Crime Academy. He has certification in Trade-Based Money Laundering from the Canadian Securities Institute, and certification in "BSA/AML: An In-Depth Look" from the Bank Administration Institute, USA.

Roel Kerckhoffs

Roel began his career serving as a tax advisor from 1989 to 1994 at various tax consultancy firms. He then transitioned into private law practice, becoming a partner at the boutique law firm Hertoghs advocaten in 1999. Specializing in financial fraud and penal tax disputes, he defended corporate and private clients until 2021. Currently, Roel serves as a public prosecutor for fraud cases at the Prosecution Department for fraud cases in Rotterdam (Rotterdam's Functioneel Parket).

Sacha Leeman

Sacha serves as a Public Prosecutor at the Dutch Prosecution Department, with a focus on the complexities of white-collar crimes, Sacha’s expertise is particularly robust in the area of tax fraud. Prior to this, Sacha worked as a tax lawyer within a prestigious law firm known for its expansive international network.

Irena Marasović

Irena serves as a Deputy Municipal State Attorney at the Municipal Criminal State Attorney’s Office in Zagreb. Formerly, she worked as a legal advisor in the Office for the Suppression of Corruption and Organized Crime in Zagreb (USKOK) specializing in crimes against the economy including tax evasion, fraud, insider trading, and money laundering, also in connection with organized crime.

Vasileios K. Petropoulos

Vasileios is an Assistant Professor at the University of Athens Law School, and specializes in Criminal Law and Procedure. Since 2003, he's been practicing law and is a Patras Bar Association member. Vasileios earned his law degree in Athens, a PhD in Munich on Criminal Law, and another in Zurich on Capital Market Criminal Law. He's a postgraduate Criminal Law lecturer at the Hellenic Open University and holds memberships in Greek and International Penal Law Associations. Fluent in German and English, he's also a research fellow with international experience.

Emanuele Piano

Emanuele is an independent award-winning investigative journalist, program creator, and author. Freelancer specializing in Africa and international current affairs. Criminal organizations have been the focus of his work for the past 15 years, from the Italian Mafias to match-fixing syndicates, from the exploitation of illegal migrant labor up to the Vatican Bank IOR. His reports have been featured, among others, on Italian State Broadcaster RAI, Sky, and Al Jazeera in English. He co-authored "The Launderer? On the trail of the Italian mafia’s dirty money." He runs Invisible Dog, an investigative journalism-oriented production company.

Matei Rosca

Matei is a journalist who specializes in international politics, economic crime, and investigations. He owns Reporter.London, a new journalism agency aiming to collaborate with established media on exclusive stories. He is also a correspondent for the International Consortium of Investigative Journalists, a nonprofit media organization based in Washington, DC. Matei has recently published the article entitled "UK authorities criticized for failing to prosecute financial crime enablers and rich tax cheats" on the International Consortium of Investigative Journalists platform.

Gianfranco Scarfò

Gianfranco is an Italian prosecutor with a diverse background in criminal law. He has served in the Prosecution Offices of Palermo and Naples, where he worked in two distinct areas: Financial and Economic Crimes as well as the Anti-Mafia Sections. In 2020, he transitioned to a specialized role focusing on crimes against the Public Administration. Additionally, in 2017, he was assigned to the Anti-Terrorism Section. As of October 2022, Gianfranco took on a leadership role as the Deputy Chief Prosecutor at the Prosecution Office of Benevento, where he leads the Financial and Economic Crimes Section.

Bernd Schlenther

Bernd is an independent expert who assists governments in improving domestic resource mobilization (DRM) and in addressing illicit financial flows (IFFs). He focuses on taxation, customs, enforcement, compliance, anti-money laundering, risk management, and intelligence. Bernd has more than 25 years of operational and management experience in public administration, notably, at the South African Revenue Service (SARS) and the African Tax Administration Forum (ATAF). He holds a PhD in Tax Policy from the African Tax Institute (ATI) of the University of Pretoria where he is also an extraordinary lecturer.

Laureen Snider

Laureen is an Emeritus Professor of Sociology at Queen's University, Kingston, Ontario. She has written extensively on corporate crime, crimes of the powerful, surveillance/technology, punishment, and the criminalization of women. Recent publications include "Big Money, Small Tax" (2018), "Beyond Trump: Neoliberal Capitalism and the Abolition of Corporate Crime" (2019), and "Revisiting Crimes of the Powerful: Marxism, Crime and Deviance" (2020). She is presently doing research on tax evasion as part of an SSHRC-funded study on Corruption in Canada with S. Bittle (the PI), J. Frauley, and J. Quaid.

Sergio Spadaro

Sergio serves as the European Delegated Prosecutor in the Milan office. After having a Ph.D. in “International and Comparative Criminal Law” from the University of Pavia, he worked as a Prosecutor in Milan, since 2002, specializing in white-collar crimes, tax offenses, money laundering, international corruption, and judicial cooperation, handling several high-profile cases on tax frauds and international corruption. In 2021 he joined the European Public Prosecutor Office (EPPO), the new EU institution with competence over the offences affecting the EU budget.

Brandon A. Sullivan

Brandon is an independent scholar and former Professor of Criminal Justice at Michigan State and Indiana University. He is an expert on enterprise and financial crimes, including tax fraud. He has extensively researched tax crimes committed by political and religious extremists, including frivolous legal arguments used by tax professionals and others engaging in ideological and profit-motivated tax avoidance. His research has been funded by the U.S. Departments of Justice and Homeland Security.

Massimiliano Vincenti

Massimiliano holds degrees in Economics and in Political Sciences, in addition to being a lawyer and chartered accountant. He is currently an Investigator for the European Anti-fraud Office of the European Commission in Brussels. He has held several positions as a Commander of Units in the Guardia di Finanza, was nominated Deputy Chief of the Financial Investigation Unit in the framework of UNMIK mission in Pristina to tackle corruption in public tenders, worked in the Guardia di Finanza anti-EU funds frauds unit and ran the Guardia di Finanza Public Finance Guardianship in Catania, Sicily.

Richard Weber

Richard is a partner at Winston & Strawn LLP in the US. Previously, he served as the Chief of the Criminal Investigation Division at the IRS, part of the U.S. Department of the Treasury. Additionally, he has held positions such as General Counsel of the NYS Department of Financial Services, Head of the Asset Forfeiture and Money Laundering Section at the Department of Justice, Deputy Chief of the Investigations Division, and Chief of the Major Economic Crimes Bureau at the Manhattan DA's Office, and federal prosecutor in the United States Attorney's Office, Eastern District of New York.

Dianne Willman

Dianne is currently appointed as Head of legal within the Asset Forfeiture Unit which position she has held for the past 4 years, prior to which she held the position of Head of Training and Development. Dianne has served within the AFU since 2002 after a period of service as a prosecutor. Dianne has significant litigation experience in asset recovery and conducts training for asset recovery practitioners both within the Unit and on the African continent. She is also seized with policy and legislative development in this field..

Simon York

Simon is a Senior Associate Fellow at the Royal United Services Institute (RUSI). Most recently, he spent 7 years as His Majesty’s Revenue and Customs Chief Investigation Officer and Director of HMRC’s Fraud Investigation Service (FIS). Simon was the first Director of FIS, building an organization able to deploy a wide range of techniques, capabilities, and powers (including criminal investigations) to tackle serious tax fraud and money laundering. Under Simon’s leadership, his teams have recovered or prevented the loss of close to £40bn in tax revenues and run criminal investigations which have led to around 4,000 convictions.

VIDEO RECORDINGS

Suggested Citation

BLUEBOOK: [Name Surname], ‘Compliance, Avoidance, and Evasion in Taxation: The Role of Professionals - The Dark Area’ CORPORATE CRIME OBSERVATORY, [Opening Remarks/Case Study/Thematic Area (1)/Thematic Area (2)] at [00:00] (Nov. 10, 2023), www.corporatecrime.co.uk/professionals-tax-compliance-and-abuse

APA: [Surname, Initial] (2023, Nov. 10). ‘Compliance, Avoidance, and Evasion in Taxation: The Role of Professionals - The Dark Area’. Corporate Crime Observatory. Video recording [Opening Remarks/Case Study/Thematic Area (1)/Thematic Area (2)] at [00:00]. Retrieved from www.corporatecrime.co.uk/professionals-tax-compliance-and-abuse

HARVARD: [Surname, Initial] (2023) ‘Compliance, Avoidance, and Evasion in Taxation: The Role of Professionals - The Dark Area’. Corporate Crime Observatory. Video recording [Opening Remarks/Case Study/Thematic Area (1)/Thematic Area (2)] at [00:00]. Available at: www.corporatecrime.co.uk/professionals-tax-compliance-and-abuse

OSCOLA: [Name Surname], ‘Compliance, Avoidance, and Evasion in Taxation: The Role of Professionals - The Dark Area’, (Corporate Crime Observatory, 10 November 2023), video recording [Opening Remarks/Case Study/Thematic Area (1)/Thematic Area (2)] at [00:00] <www.corporatecrime.co.uk/professionals-tax-compliance-and-abuse>

Compliance, Avoidance, and Evasion in Taxation: The Role of Professionals - The Dark Area
Opening Remarks: Dr. Costantino Grasso

Compliance, Avoidance, and Evasion in Taxation: The Role of Professionals - The Dark Area
Case Study - Tax Crime Beyond Borders: Understanding the Distorted Dynamics of Offshore Business
(Rudolf Elmer)

Compliance, Avoidance, and Evasion in Taxation: The Role of Professionals - The Dark Area
Thematic Area (1): Evasion and Enablers: The Dark Side of Tax Professionals

This section explores the involvement of professionals in the dark area of taxation marked by unethical and criminal forms of conduct. It scrutinizes the participation of tax professionals or related firms in the perpetration of tax crimes by investigating both their failure to prevent clients from engaging in criminal activities and their direct involvement in committing these offenses. The experts will discuss the methods employed by professionals to facilitate or enable these unlawful actions without facing legal consequences, potentially involving strategies to avoid detection or liability while still being complicit in or aiding criminal actions related to taxation. Furthermore, the session will focus on the ways to detect and punish the professionals, or their organizations, involved in such criminal activities to explore the legal approaches used to hold them accountable, including criminalization, investigative techniques, and other enforcement strategies. It will also examine the challenges encountered by professional associations, investigators, prosecutors, and judges when seeking to counter such behavior.

Compliance, Avoidance, and Evasion in Taxation: The Role of Professionals - The Dark Area
Thematic Area (2): Tax Crimes and Beyond: Exploring the Role of Professionals in Interlinked Criminal Offenses

This section examines the role of professionals in situations where criminal activities present interlinks between tax crimes and other offenses such as organized crime, money laundering, and corruption. One of its primary objectives is to discuss and shed light on the role that tax professionals play in these complex, interconnected spheres of criminal conduct. In particular, this section explores how the nature and features of professionals’ participation change when they are involved in these interconnected criminal practices, and assesses the societal risks posed by such dual or multiple involvements. A focus is placed on the evolving networks and relationships among professionals, clients, and financial institutions, especially as they relate to secrecy, compartmentalization, and potential network expansion. Finally, it discusses the variances in investigative, prosecutorial, and judicial approaches when dealing with professionals implicated in these interrelated spheres of criminal conduct.

THE BRIGHT AREA

THE GRAY AREA (SESSION 1)

THE GRAY AREA (SESSION 2)

THE DARK AREA

COMPLIANCE, AVOIDANCE, AND EVASION IN TAXATION: THE ROLE OF PROFESSIONALS

COMPLIANCE, AVOIDANCE, AND EVASION IN TAXATION:
THE ROLE OF PROFESSIONALS