Zhanna A. Ziering is a Member in Caplin & Drysdale's New York office. She offers guidance to individual and corporate clients who require sophisticated tax advice concerning their domestic tax issues, offshore assets, and U.S. reporting requirements.
Clients rely on Ms. Ziering's deep knowledge of tax controversies and tax litigation, as well as her experience with related civil, criminal, and regulatory proceedings. Ms. Ziering represents both individuals and corporations before the U.S. Tax Court, federal and state courts, and administrative agencies, including the Internal Revenue Service, the Department of Justice, and other federal and state government regulators. Illustrations of Ms. Ziering's services include:
- advising clients on sensitive civil tax examinations by the IRS where fraud or substantial penalty issues may arise;
- counseling advisors and other professionals on tax matters arising from investigations with U.S. regulators; and
- defending clients in U.S. and state residency audits.
Ms. Ziering also serves as trusted counsel for clients facing offshore voluntary disclosure requirements on the federal and state levels. She advises clients on their U.S. tax reporting obligations relating to offshore assets and interests, and assists in responding to audits and inquiries from the IRS and other government agencies. Representative examples of Ms. Ziering's legal services include:
- advising U.S. citizens living or working abroad, foreign nationals residing and working in the U.S., and foreign entities doing business in the U.S. about coming into tax compliance concerning their foreign accounts and
- representing clients in civil tax dispute with New York and New Jersey.
Ms. Ziering speaks fluent Russian.
A strong supporter of the arts, Ms. Ziering offers pro bono tax representation to artists from a diverse range of industries, such as film, music, and fashion. She also provided counsel to low-income taxpayers with a broad range of tax issues through Duke University School of Law's Low-Income Taxpayer Clinic and New York University School of Law's Tax Clinic.
An active member of the legal community, Ms. Ziering currently serves as Subcommittee Chair for the Membership and Young Lawyer Liaison of the American Bar Association's Section of Taxation, Court Procedure and Practice Committee. To stay abreast of ever-changing tax laws, she is also a proactive member in the Tax Sections of the New York State Bar Association and the New York County Lawyers' Association.
An avid lecturer on matters relating to tax law, Ms. Ziering has spoken on the following topics:
- Speaker, Section on Taxation: Developments in FBAR Litigation and Enforcement, Federal Bar Association, December 17, 2020
- Panelist, FBAR Investigations and Litigation: Compliance Traps, IRS Guidance, FBAR Defense Strategies, Recent Cases, Penalties, Strafford Publications, September 24, 2020
- Panelist, Preparing For and Managing an IRS Examination with Virtual Currency Issues, ABA Section of Taxation, 2020 ABA Midyear Meeting, January 31, 2020
- Panelist, Collections of Foreign Tax Judgments: When Your Other Problems Come Home, ABA Section of Taxation, 2020 ABA Midyear Meeting, January 31, 2020
- Panelist, Track B: Summons & Summons Enforcement, 2019 IRS Representation Conference, November 22, 2019
- Panelist, Ethical Obligations to Report Misconduct on by Other Practitioners and Taxpayers, 2019 IRS Representation Conference, November 22, 2019
- Panelist, Important Developments in Civil and Criminal Tax Penalties: Offshore Compliance and Enforcement, 2019 ABA Section of Taxation May Meeting, May 11, 2019
- Panelist, Important Developments in Civil and Criminal Tax Penalties: Offshore Compliance and Enforcement, ABA Section of Taxation, 2019 ABA Midyear Meeting, January 19, 2019
- Panelist, Litigating Foreign-Related Penalties, American Bar Association 35th National Institute on Criminal Tax Fraud and Eighth Annual National Institute on Tax Controversy, December 14, 2018
- Panelist, Civil and Criminal Tax Penalties - Reports of Subcommittees on Important Developments, American Bar Association, 2018 Fall Meeting, October 6, 2018
- Panelist, Post-Mayo Jurisprudence: Challenging Regulations after, American Bar Association, 2018 Fall Tax Meeting, October 5, 2018
- Panelist, Current Event in International Civil and Criminal Tax Enforcement, The International Tax Enforcement Update, June 14, 2018
- Panelist, Dealing with the Undocumented Worker, The Criminal Tax Case: When Criminal Investigators Come Knocking, May 17, 2018
- Panelist, Bringing Your Client in from the Cold, The Criminal Tax Case: When Criminal Investigators Come Knocking, May 17, 2018
- Panelist, Civil and Criminal Tax Penalties - Reports of Subcommittees on Important Developments, 2018 ABA Section of Taxation May Meeting, May 12, 2018
- Panelist, Ethics Issues in Criminal Representations, 2018 ABA Section of Taxation May Meeting, May 11, 2018
- Panelist, Taking Positions Contrary to Regulations: Update on Deference and Disclosure, NYLS 15th Annual Tax Lawyering Workshop, May 3, 2018
- Panelist, Civil and Criminal Tax Penalties: Reports of Subcommittees on Important Developments - Offshore Compliance and Enforcement, American Bar Association Section of Taxation 2018 Midyear Meeting, February 10, 2018
- Panelist, Tax Collection, Bankruptcy and Workouts: Recent Developments, American Bar Association Section of Taxation 2018 Midyear Meeting, February 9, 2018
- Panelist, Waking Up the Dead: Reopening Those Tax Assessments You Thought Were Final, New England IRS Representation Conference, November 17, 2017
- Speaker, Important Developments in Civil and Criminal Tax Penalties, ABA Section of Taxation, 2017 Joint Fall CLE Meeting, September 16, 2017
- Presenter, Developments in FBAR Litigation, American Bar Association, Section of Taxation, Administrative Practice Committee, July 19, 2017
- Presenter, International Tax Enforcement Update, Civil and Criminal International Tax Enforcement Update, June 14, 2017
- Panelist, International Information Reporting, 2017 ABA Section of Taxation May Meeting, May 13, 2017
- Presenter, Offshore Enforcement Update, 2017 ABA Section of Taxation May Meeting, May 13, 2017
- Panelist, How to Affirmatively Defend An FBAR Case, American Bar Association, 2017 Midyear Meeting, January 20, 2017
- Moderator, It's a Small World After All: Evidence in Offshore NonCompliance Cases (Part II), American Bar Association, 2016 Joint Fall Meeting, October 1, 2016
- Moderator, It's a Small World After All: Evidence in Offshore NonCompliance Cases (Part I), American Bar Association, 2016 Joint Fall Meeting, September 30, 2016
- Speaker, The International Enforcement Arena, American Academy of Attorney-CPAs, June 24, 2016
- Speaker, One Taxpayer's Underpayment is Another's Treasure: Whistleblower Awards Under Section 7623, American Academy of Attorney-CPAs, June 24, 2016
- Speaker, Nuts & Bolts of Tax Court Litigation: Pre-Trial, ABA Tax Section, January 30, 2016
- Speaker, The Other Shoe is Dropping - Criminal Enforcement and Civil Assessment and Collection of FBAR and International Information Return Penalties, ABA Tax Section, January 29, 2016
- Navigating U.S. Tax Requirements and Strategic Methods of Coming into Compliance, Caplin & Drysdale, Chartered and Ham, Langston & Brezina LLP, U.S. Tax Requirements and Compliance Seminar, March 11, 2015
- Panelist, Offshore Account Disclosure Case Update, American Bar Association, 2015 Midyear Meeting, January 30, 2015
- Panelist, 2014 OVDP and Streamlined Procedures – An Update, American Bar Association, 2014 Joint Fall CLE Meeting, September 20, 2014
- Panelist, IRS Offshore Voluntary Disclosure Program - Version 3.0: Including Streamlined Rules That Are A Game Changer, State Bar of California, July 17, 2014
- Panelist, The Nuts & Bolts of Deficiency Cases - From Examination to the Tax Court, American Bar Association, 2013 May Meeting, May 9, 2013
- Moderator, Through the Looking Glass (Part II): Opting Out of the OVDI Penalty Structure and Litigating FBAR Penalties, American Bar Association, Live CLE Webinar & Teleconference, April 10, 2013
- Moderator, Through the Looking Glass (Part III): Collecting and Litigating FBAR Penalties, American Bar Association, 2013 Midyear Meeting, January 25, 2013
- Moderator, Through the Looking Glass (Parts I and II): Opting Out of the OVDI Penalty Structure and Litigating FBAR Penalties, American Bar Association, Webinar, January 16, 2013
- Moderator, Through the Looking Glass (Part II): Litigating FBAR Penalties, American Bar Association, 2012 Joint Fall CLE Meeting, September 14, 2012
- Moderator, Nuts & Bolts of Deficiency Cases: From Examination to the Tax Court, American Bar Association, 2012 May Meeting, May 10, 2012
- Moderator, Court Procedure Issues in CDP Judicial Review, American Bar Association, 2012 Midyear Meeting, February 17, 2012
- Speaker, Current Developments in Court Procedure and Practice, American Bar Association, 2011 Joint Fall CLE Meeting, October 21, 2011
- Speaker, Court Procedure and Practice: Current Developments, American Bar Association, 2011 Midyear Meeting, January 21, 2011
- Speaker, Judicial Deference Mock Argument: Application of Temp. Treas. Reg. § 301.6501(e)-1T(a)(1)(iii) in Smith v. Commissioner, American Bar Association, 2010 Midyear Meeting, January 21, 2010
Click here for a full list of speaking engagements.
- "The IRS Resumes its Global High-Wealth Examination Program and Targets High Income Non-Filers,"
with Dianne C. Mehany, Victor A. Jaramillo, Scott D. Michel, and Mark E. Matthews, Caplin & Drysdale Client Alert, July 22, 2020
- "Damage Mitigation: The IRS Helps Alleviate Effect of COVID-19 on U.S. and Foreign Residency,"
with Dianne C. Mehany, Victor A. Jaramillo, and Jonathan R. Black, Caplin & Drysdale Client Alert, April 22, 2020
- "Updated Filing and Payment Extensions Under Notice 2020-23,"
with Dianne C. Mehany, Victor A. Jaramillo, Scott D. Michel, and Aaron M. Esman, Caplin & Drysdale Client Alert, April 10, 2020
- "Collateral Damage: Covid-19 and its Unintended Effect on U.S. Residency,"
with Dianne C. Mehany and Victor A. Jaramillo, Caplin & Drysdale Client Alert, April 1, 2020
- "The Impact of Notice 2020-18 on Information Returns,"
with Dianne C. Mehany, Victor A. Jaramillo, and Aaron M. Esman, Caplin & Drysdale Client Alert, March 30, 2020
- "New Cryptocurrency Guidance,"
with Victor A. Jaramillo, Caplin & Drysdale Client Alert, October 22, 2019
- "Decrypting The New IRS Cryptocurrency Compliance Letters,"
with Victor A. Jaramillo, Law360 Tax Authority, August 7, 2019
- "Cryptocurrency Criminal Tax Cases Coming Soon,"
with Victor A. Jaramillo, Mark E. Matthews, and Scott D. Michel, Caplin & Drysdale Client Alert, July 23, 2019
- "Deal or No Deal: The Unknown Cost of the IRS's New Voluntary Disclosure Practice,"
White Collar Crime Committee Newsletter, February 28, 2019
- "The New Voluntary Disclosure Practice: A Fair Compromise?,"
with Dianne C. Mehany, Scott D. Michel, and Mark E. Matthews, Caplin & Drysdale Client Alert, December 3, 2018
- "INSIGHT: Last Call for OVDP: Use It or Lose It,"
with Benjamin Z. Eisenstat, Bloomberg Tax: Daily Tax Report, April 20, 2018
- "IRS's Offshore Voluntary Disclosure Program Ending: Impact on U.S. Taxpayers,"
with Benjamin Z. Eisenstat, Scott D. Michel, Dianne C. Mehany, and Mark E. Matthews, Caplin & Drysdale Client Alert, March 14, 2018
- "IRS to Revoke Passports for Seriously Delinquent Tax Debts Starting February 2018,"
with Dianne C. Mehany, Mark D. Allison, Victor A. Jaramillo, and Christopher S. Rizek, Caplin & Drysdale Client Alert, February 12, 2018
- "Paradise Papers: U.S. Citizens and Residents Required to Report on Offshore Assets,"
with Mark D. Allison, J. Clark Armitage, Peter A. Barnes, and Kirsten Burmester, Caplin & Drysdale Client Alert, November 6, 2017
- "IRS Launches Issue Based Corporate Compliance Campaigns,"
with Mark D. Allison, J. Clark Armitage, Kirsten Burmester, and Niles A. Elber, Global Tax Weekly, February 16, 2017
- "IRS Launches 13 Issue-Based Corporate Compliance Campaigns,"
with Mark D. Allison, J. Clark Armitage, Kirsten Burmester, and Niles A. Elber, Caplin & Drysdale Client Alert, February 3, 2017
- "Report of Foreign Bank and Financial Accounts (FBAR)" (Book),
with Mark E. Matthews and Niles A. Elber, Bloomberg BNA's Tax Management Portfolio, June 29, 2016
- "U.S. Passports in Jeopardy for Taxpayers Owing the IRS,"
with Niles A. Elber, Dianne C. Mehany, and Victor A. Jaramillo, Caplin & Drysdale Client Alert, December 9, 2015
- "New Law Changes FBAR Filing Deadline,"
with Charles M. Ruchelman, Mark D. Allison, Niles A. Elber, and Mark E. Matthews, Caplin & Drysdale Client Alert, August 10, 2015
- "U.S. Offshore Account Enforcement Issues,"
with Scott D. Michel, CCH's Journal of Tax Practice & Procedure, September 30, 2014
- "IRS Issues Final Regulations on Material Advisor Penalties,"
with Christopher S. Rizek, Mark D. Allison, and Rachel L. Partain, Caplin & Drysdale Client Alert, August 4, 2014
- "IRS Modifies Offshore Voluntary Disclosure Program and Streamlined Filing Compliance Procedures,"
with Scott D. Michel, Caplin & Drysdale Client Alert, June 23, 2014
- "The Nuts And Bolts of Deficiency Cases: From Examination to The Tax Court,"
The Practical Tax Lawyer, December 1, 2012
- "Comments to the Proposed Amendments to the Rules of the United States Tax Court,"
American Bar Association, March 7, 2011
- "Comments to the Proposed Amendments to the Rules of the United States Tax Court,"
American Bar Association, May 27, 2009
- "Selected Recent Developments in Administrative Practice,"
American Bar Association (May Meeting, Administrative Practice Committee), May 8, 2009
Click here for a full list of publications.
