Zhanna A. Ziering is a Senior Associate 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.
Recent Speaking Engagements
An avid lecturer on matters relating to tax law, Ms. Ziering has spoken on the following topics:
- Speaker, One Taxpayer's Underpayment is Another's Treasure: Whistleblower Awards Under Section 7623, American Academy of Attorney-CPAs, June 24, 2016
- Speaker, The International Enforcement Arena, 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, New and Improved June 2014 IRS Offshrore Voluntary Disclosure Program - Version 3.0: Including Streamlined Rules That Are A Game Changer, State Bar of California, Webinar, 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