Zhanna A. Ziering

Zhanna A. Ziering: Attorney with Caplin & Drysdale, Chartered
  • Member at Caplin & Drysdale, Chartered (68 Attorneys)
  • 600 Lexington Avenue, 21st Floor, New York, NY 10022
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Biography

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.

Services

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.

Highlights

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.

Awards & Rankings

The Legal 500, Next Generation Lawyers, 2018; Recommended, 2017-Present
Super Lawyers, New York Rising Star, 2013-Present
The American Lawyer's Global Legal Award, Global Dispute of the Year: Investigations, Swiss Tax Settlements, 2015
Nolan Fellowship, American Bar Association, Section of Taxation, 2013

Recent News

•Tax Notes Quotes Zhanna Ziering: Court Finds FBAR Willfulness for Schedule B Failure, Little Else , Tax Notes, January 23, 2019
•10 Caplin & Drysdale Attorneys Contribute to ABA's Annual Section of Taxation Midyear Meeting , January 3, 2019
•Law360 Comments on Danish Tax Fraud Case Letter from Caplin & Drysdale Attorneys , Law360 Tax Authority, October 29, 2018
•Zhanna Ziering Comments on Temporary Regs' Validity Without Notice and Comment , Tax Notes, October 10, 2018
•7 Caplin & Drysdale Attorneys Contribute to ABA's Annual Section of Taxation Fall Meeting , Caplin & Drysdale, October 2, 2018
•Zhanna Ziering Speaks to Worldwide Tax Daily on Constructive Knowledge Not Enough for FBAR Willfulness , Tax Notes, August 24, 2018
•Worldwide Tax Daily Quotes Zhanna Ziering: Courts' Split on FBAR Penalty Cap Creates Litigation Ripples , Tax Analysts, August 17, 2018
•Zhanna Ziering Talks to Tax Analysts on FBAR Penalties , Tax Analysts, August 2, 2018
•Tax Analysts Quotes Zhanna Ziering: Another Court Finds FBAR Penalties Can't Exceed $100,000 , Tax Analysts, July 20, 2018
•Zhanna Ziering Comments on FBAR Penalty Case , MLex US Tax Watch, July 13, 2018
•Zhanna Ziering Comments on Colliot and Wahdan Cases , Tax Analysts, June 26, 2018
•Zhanna Ziering Comments on Colliot Decision Impacting FBAR , MLex US Tax Watch, June 8, 2018
•2018 Legal 500 Distinguishes 18 Caplin & Drysdale Attorneys, Firm Renews Top-Tier Firm Ranking for Tax Controversy , The Legal 500, May 31, 2018
•Tax Notes Quotes Zhanna Ziering on Potential Pivotal Consequences of FBAR Order , Tax Notes, May 21, 2018
•9 Caplin & Drysdale Attorneys Contribute to ABA's Annual Section of Taxation Meeting , Caplin & Drysdale, May 9, 2018
•Zhanna Ziering Comments on the Government's Third Circuit Brief in Bedrosian , Bloomberg BNA, Daily Tax Report: International, April 26, 2018
•U.S. News Quotes Zhanna Ziering on Risks Related to Holding an Offshore Account , U.S. News & World Report, April 26, 2018
•Mark Matthews and Zhanna Ziering Discuss Rise in U.S. International Tax Prosecutions with Daily Tax Report , Daily Tax Report, December 28, 2017
•Tax Notes Quotes Zhanna Ziering: Government Appeals FBAR Loss in Bedrosian , Tax Notes, November 20, 2017
•Tax Notes Quotes 3 Caplin Tax Controversy Attorneys on the IRS's Aggressive FBAR Enforcement , Tax Notes, October 19, 2017
•Mark Allison and Zhanna Ziering Listed Among New York's Top Tax Lawyers , Super Lawyers , October 3, 2017
•Tax Notes Quotes Zhanna Ziering: FBAR Decision Shows IRS Winning on Willfulness, Practitioner Says , Tax Notes, September 25, 2017
•Zhanna Ziering Speaks to Tax Notes on Reasonable Cause Defense in FBAR Case , Tax Notes, July 6, 2017
•18 Caplin & Drysdale Lawyers Recognized in 2017 Legal 500 Ranking , The Legal 500, June 2, 2017
•Zhanna Ziering Comments on U.S. Enforcement of FBAR Violations with Tax Notes , Tax Notes, May 26, 2017
•Caplin & Drysdale Promotes Zhanna Ziering to Member , Caplin & Drysdale, October 3, 2016
•NY Super Lawyers Lists Mark Allison and Zhanna Ziering for Tax Law , Super Lawyers, September 21, 2016
•Tax Notes Quotes Zhanna Ziering: News Analysis: Did You Really Mean to Hide Those Foreign Accounts? , Tax Notes, July 11, 2016
•Caplin & Drysdale Attorneys Offer Comprehensive Guide on FBAR Reporting Requirements , Caplin & Drysdale, June 29, 2016
•Worldwide Tax Daily Quotes Zhanna Ziering on New FBAR Rule , Worldwide Tax Daily, March 3, 2016
•Tax Notes Today Quotes Zhanna Ziering on Reasonable Cause Relief at 2016 ABA Midyear Meeting , Tax Notes Today, February 2, 2016
•Caplin & Drysdale Lawyers Listed Among NY's Super Lawyers , Caplin & Drysdale, September 16, 2015
The American Lawyer Names Caplin & Drysdale Global Legal Award Recipient for Swiss Tax Investigations , The American Lawyer, July 31, 2015
•Dianne Mehany and Zhanna Ziering Talk to CNS Business: There's No Hiding from Uncle Sam , CNS Business, March 13, 2015
•CNS Business Features Dianne Mehany and Zhanna Ziering on Seminar to Help U.S. Taxpayers in Cayman , CNS Business, March 3, 2015
•Worldwide Tax Daily Quotes Zhanna Ziering on IRS's Streamlined Program at 2015 ABA Midyear Meeting , Worldwide Tax Daily, February 3, 2015
•Mark Allison, Rachel Partain, and Zhanna Ziering Listed Among New York's Super Lawyers , Super Lawyers, September 24, 2014
•New York State Tax Crackdown Requires Prompt Action on Past-Due Taxes , Caplin & Drysdale, August 7, 2013
•Super Lawyers Lists Nineteen Caplin & Drysdale Attorneys , Super Lawyers, April 29, 2013
•Zhanna Ziering Named ABA 2013 Nolan Fellow , January 28, 2013
•Caplin & Drysdale Announces Expansion of Tax Practice and Relocation of New York Office , September 20, 2012

Recent Speaking Engagements

An avid lecturer on matters relating to tax law, Ms. Ziering has spoken on the following topics:

•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, 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

Recent Publications

• The New Voluntary Disclosure Practice: A Fair Compromise? , with Dianne C. Mehany, Arielle M. Borsos, Scott D. Michel, and Mark E. Matthews, Caplin & Drysdale Client Alert, December 3, 2018

January 28, 2013
•Caplin & Drysdale Announces Expansion of Tax Practice and Relocation of New York Office, Caplin & Drysdale, September 20, 2012 Member:

Professional Activities

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. Fellow: , January 28, 2013
•Caplin & Drysdale Announces Expansion of Tax Practice and Relocation of New York Office , Caplin & Drysdale, September 20, 2012 Member:

Professional Activities

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. Fellow: January 28, 2013
•Caplin & Drysdale Announces Expansion of Tax Practice and Relocation of New York Office, Caplin & Drysdale, September 20, 2012 Member:

Professional Activities

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. Fellow: 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.

Areas of Practice (4)

  • Tax Controversies
  • Tax Crimes
  • Tax Litigation
  • International Tax

Education & Credentials

Contact Information:
(212) 379-6075  Phone
(212) 379-6001  Fax
www.caplindrysdale.com/zziering
University Attended:
New York University, B.F.A., 1999
Law School Attended:
New York Law School, J.D., magna cum laude, 2006; New York University School of Law, LL.M., 2007
Year of First Admission:
2008
Admission:
New York; New Jersey; District of Columbia; U.S. District Court for the Eastern District of New York; U.S. Court of Federal Claims; U.S. District Court for the Southern District of New York; U.S. Tax Court
Memberships:

Professional Activities

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.

ISLN:
918592901

Peer Reviews

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*Peer Reviews provided before April 15, 2008 are not displayed.

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New York, New York

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