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Zhanna A. Ziering

Member

Contact Me:

(646) 357-3875
[email protected]

Biography

Zhanna A. Ziering, a tax controversy and litigation attorney, is a Member in the Firm’s New York office. Ms. Ziering’s practice focuses on representing individual and entity clients in civil and criminal tax disputes with federal and state governments as well as in regulatory proceedings. She defends both individual and entity taxpayers 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.

Ms. Ziering advises taxpayers in connection with various tax issue, including those arising in connection with domestic and offshore income and assets, cryptocurrency, and U.S. tax and regulatory reporting requirements. She approaches each of her client engagements with empathy and kindness and develops a strategy for dispute resolution by taking the client’s views, needs, and resources into consideration. When faced with alternatives for dispute resolution, Ms. Ziering discusses the various available options, and the benefits and drawbacks of each such option, with the clients and works together with them to develop the approach tailored to that particular client and situation.

Ms. Ziering strives to resolve every tax dispute that her clients are facing amicably and efficiently while zealously advocating on her clients’ behalf. Her significant experience in representing clients in various stages of a tax dispute allows her to aptly navigate the procedural hurdles and achieve best results possible under the circumstances for each client.

A well-regarded member of the legal community, Ms. Ziering is actively engaged in American Bar Association, Section of Taxation. She currently serves as the Vice Chair of Court Practice and Procedure Committee. Ms. Ziering is also a sought-after speaker and writer on various topics relating to tax controversy and litigation. She is a co-author of the Bloomberg BNA’s Tax Management Portfolio, Report of Foreign Bank and Financial Accounts.

An avid supporter of the arts, Ms. Ziering had offered 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.

Ms. Ziering lives in New Jersey with her husband, two rambunctious boys, and a Chocolate Labrador, named Mr. Chance Broadway. Ms. Ziering is a native Russian speaker and insists on reading all the great Russian literature in its original language.

Experience

Representative examples of Ms. Ziering’s legal services include:

  • Representing clients in a district court litigation relating to FBAR penalties;
  • 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 assets and business interests;
  • Representing clients in 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;
  • Defending clients in U.S. and state residency audits;
  • Guiding clients through various stages of tax disputes with the IRS resulting their domestic and offshore holdings;
  • Representing clients in civil and criminal tax disputes with New York and New Jersey in connection with the employment tax and sales tax issues; and
  • Defending clients in criminal investigations and civil examinations in connection with underpayments and/ or underreporting of employment tax.

Education

  • New York University School of Law
    • LL.M. – 2007
  • New York Law School
    • J.D. – 2006
    • Honors: magna cum laude
  • New York University
    • B.F.A. – 1999

Court Admissions

  • New York
  • New Jersey
  • District of Columbia
  • U.S. Supreme Court
  • U.S. Court of Appeals for the Second Circuit
  • U.S. Tax Court
  • U.S. Court of Federal Claims
  • U.S. District Court, Southern District of New York
  • U.S. District Court, Eastern District of New York
  • U.S. District Court, Western District of New York
  • U.S. District Court of New Jersey

Publications

  • Zhanna Ziering and Aaron Esman pen American Bar Association Section of Taxation comments on proposed amendments to the Tax Court rules of practice and procedure, May 25, 2022.  Read the comments here.
  • “Decrypting The New IRS Cryptocurrency Compliance Letters”, with Victor A. Jaramillo, Law360 Tax Authority, August 7, 2019
  • “Deal or No Deal: The Unknown Cost of the IRS’s New Voluntary Disclosure Practice”, with Arielle Borsos, White Collar Crime Committee Newsletter, February 28, 2019
  • “INSIGHT: Last call for OVDP: Use It or Lose It”, with Ben Eisenstat, Bloomberg Tax: Daily Tax Report, April 20, 2018
  • “IRS Launches Issue Based Corporate Compliance Campaigns”, Global Tax Weekly, February 16, 2017
  • Report of Foreign Bank and Financial Accounts (FBAR), (Book), Co-Author, Bloomberg BNA’s Tax Management Portfolio, June 29, 2016,
  • “U.S. Offshore Account Enforcement Issues”, CCH’s Journal of Tax Practice & Procedure, September 30, 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

Professional Involvement

  • Fellow, American College of Tax Counsel
  • American Bar Association, Section of Taxation
    • Current Vice-Chair of the Court Practice and Procedure Committee
    • Former Co-Chair of Subcommittee on Offshore Enforcement for Civil and Criminal Tax Penalties Committee
  • New York State Bar Association
  • Federal Bar Association

Honors

  • The Legal 500, Next Generation Lawyers, 2018-Present; Recommended, 2017 – Present
  • Super Lawyers New York Rising Star, 2013 – 2017; Super Lawyers in Tax (New York Metro List), 2023
  • Best Lawyers in America, 2021
  • 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

Speaking Engagements

Previous Speaking Engagements

2023

  • Zhanna Ziering spoke on “When You Should Know Something That the Government Does Not: Ethical Considerations in Keeping Your Civil Case from Going Criminal” panel at the 2023 ABA 40th Annual National Institute on Criminal Tax Fraud in Las Vegas, NV on December 8, 2023
  • Zhanna Ziering moderated the “IRS Enforcement Around Employee Retention Credits” panel at the 2023 IRS Tax Representation Conference on December 1, 2023.
  • Zhanna Ziering spoke on a panel at the NYU Tax Controversy Forum in New York on June 10, 2023, regarding the FBAR penalties that IRS issues and the impact of the Supreme Court’s decision in Bittner v. U.S.
  • Zhanna Ziering presented at the Federal Bar Association Tax Law Conference on March 6, 2023 on cryptocurrencies.  Details are to follow.

2022

  • Zhanna Ziering presented on “Ethics Issues Presented by Conflicts of Interest in Tax Cases—Caution is the Watchword” at 2022 American Bar Association 39th National Institute on Criminal Tax Fraud and 12th Annual National Institute on Tax Controversy, December 11 -13, 2022, Las Vegas.
  • Zhanna Ziering presented at the 2022 New England IRS Representation Conference in New Haven, CT on November 18, 2022 on “Estate & Gift Update Part 2: Pitfalls When Handling the Estate and Why the Tax Returns Matter!” and “Gotcha: Challenging Tax Penalties on International Forms.”
  • Zhanna Ziering presented on “Litigation Update: The Latest on FBAR and Other International Information Return Penalties” for DC Bar Association (virtual), June 30, 2022.
  • Zhanna Ziering presented on “Cryptocurrency Update” and “Cleaning Up the Client’s Mess-Voluntary Disclosure” at the Criminal Tax Day 2022, Live in-person and Webcast Event, Quinnipiac University School of Law, New Haven, CT,  June 10, 2022.
  • Guinevere Moore and Zhanna Ziering presented on “Foreign Financial Asset Reporting-Learn From Tax Attorneys” on a webinar hosted by CDH CPA (May 19, 2022).
  • Panelist for “Structuring a Tax Representation: Privilege, Fees and Other Considerations” 19th Annual Tax Lawyering Workshop: Tax Practice in a Changing World, New York Law School (April 29, 2022).
  • Panelist, “Foreign Trusts and Trust like Structures,” 2022 Tax Institute (Virtual Event), hosted by the USC Gould School of Law, January 26, 2022.

2021

  • Panelist, “The Attorney-Client Privilege and Work Product Protection in Tax Court – Developments and Best Practices (Ethics)”, 2021 American Bar Association 38th National Institute on Criminal Tax Fraud and 11th Annual National Institute on Tax Controversy, December 11-13, 2021, Las Vegas
  • Panelist, “The IRS’s Use of Data & AI in Enforcement,” 2021 IRS Representation Conference (Virtual) (November 19, 2021).
  • Panelist, “Tax Controversies,” NYU’s 80th Institute on Federal Taxation (Virtual), (November 15, 2021).
  • Panelist, “FBAR Litigation Developments,” STEP USA Webinar, (October 21, 2021)
  • Panelist, The Cost of Cheating: U.S. and U.K. Enforcement to Deter Non-Compliance, Thirty-Eighth Cambridge International Symposium on Economic Crime, Cambridge UK, September 7, 2021. CIDOEC (crimesymposium.org)
  • Speaker, Paycheck Protection Program Loan Fraud, 4th Annual Criminal Tax Day, New England, May 28, 2021

2020

  • 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, New IRS Cryptocurrency Guidance on Hard Forks and Airdrops: Rev. Rul. 2019-24, Audit Risks for U.S. Taxpayers, Strafford Publications Webinar, February 27, 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

2019

  • 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, Current Developments in FBAR Civil Penalty Litigation, Master Class, The Graduate Tax Program, New York Law School, November 20, 2019
  • Panelist, The Benefits and Limitations of Privileges: Attorney-Client (Kovel), Spousal, Accountant and Work Product, Shopping the Preparer: IRS Criminal Investigations of Tax Preparers, 3rd Annual Criminal Tax Day, New England, May 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

2018

  • 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, Litigating Title 31 FBAR Penalties: The Fundamentals, 2018 Annual Meeting of the California Tax Bar and California Tax Policy Conference, November 8, 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, American Bar Association, 2018 Fall Meeting, October 5, 2018
  • Panelist, Current Event in International Civil and Criminal Tax Enforcement, The International Tax Enforcement Update, June 14, 2018
  • Panelist, Bringing Your Client in from the Cold, The Criminal Tax Case: When Criminal Investigators Come Knocking, 2nd Annual Criminal Tax Day, New England, May 17, 2018
  • Panelist, Dealing with the Undocumented Worker, The Criminal Tax Case: When Criminal Investigators Come Knocking, 2nd Annual Criminal Tax Day, New England, 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, Tax Planning for the High Net Worth Individuals, 2018 Annual Tax Planning Strategies, U.S. and Europe, Wealth Management Program, April 11, 2018 (Amsterdam, Netherlands)
  • 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

2017

  • 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
  • Speaker, Developments in FBAR Litigation, ABA Section of Taxation, Administrative Practice Committee Monthly Call, July 19, 2017
  • Presenter, International Tax Enforcement Update, Agostino & Associates’ 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

2016

  • Moderator, It’s a Small World After All: Evidence in Offshore Non-Compliance Cases (Part II), American Bar Association, 2016 Joint Fall Meeting, October 1, 2016
  • Moderator, It’s a Small World After All: Evidence in Offshore Non-Compliance Cases (Part I), American Bar Association, 2016 Joint Fall Meeting, September 30, 2016
  • 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

2010-2015

  • Panelist, “Offshore Account Disclosure Case Update,” ABA Section of Taxation January Meeting, Court Procedure and Practice (January 30, 2015, Houston, Texas)
  • Panelist, “2014 OVDP and Streamlined Procedures – An Update,” ABA Section of Taxation Fall Meeting, Civil and Criminal Tax Penalties Committee ( September 20, 2014, Denver, Colorado)
  • Panelist, “’New and Improved’ June 2014 IRS Offshore Voluntary Disclosure Program—Version 3.0: Including ‘Streamlined’ Rules That Are Game Changer,” The State Bar of California, Taxation Section, Webinar (July 17, 2014)
  • Panelist, ABA Tax Bridge to Practice, ABA Section of Taxation May Meeting, Court Procedure and Practice (May 9, 2013, Washington D.C.)
  • Moderator, “Through the Looking Glass (Part III): Collecting and Litigating FBAR Penalties,” ABA Section of Taxation Webinar, Court Procedure and Practice Committee (April 10, 2013)
  • Moderator, “Through the Looking Glass (Part III): Collecting and Litigating FBAR Penalties,” ABA Section of Taxation January Meeting, Court Procedure and Practice Committee (January 25, 2013, Orlando, Florida)
  • Moderator, “Through the Looking Glass (Part I and II): Opting out of the OVDI Penalty Structure and Litigating FBAR Penalties,” ABA Section of Taxation Webinar, Court Procedure and Practice Committee (January 16, 2013)
  • Moderator, “Through the Looking Glass (Part II): Litigating FBAR Penalties,” ABA Section of Taxation Fall Meeting, Court Procedure and Practice Committee (September 2012, Boston, Massachusetts)
  • Moderator, “Nuts & Bolts of Deficiency Cases: From Examination to the Tax Court,” ABA Section of Taxation 2012 May Meeting, Court Procedure and Practice Committee (May 2012, Washington DC)
  • Moderator, “Court Procedure Issues in CDP Judicial Review,” ABA Section of Taxation February Meeting, Court Procedure and Practice Committee (February 2012, San Diego, California)
  • Speaker and Author, “Current Developments,” ABA Section of Taxation Fall Meeting, Court Procedure and Practice Committee (October 2011, Denver, Colorado)
  • Speaker and Author, “Current Developments,” ABA Section of Taxation January Meeting, Court Procedure and Practice Committee (January 2011, Boca Raton, Florida)
  • Speaker, “Judicial Deference Mock Argument: Application of Temp. Treas. Reg. § 301.6501(e)-1T(a)(1)(iii) in Smith v. Commissioner,” ABA Section of Taxation January Meeting, Court Procedure and Practice Committee, (January 2010, San Antonio, Texas)