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Zhanna A. Ziering - New York, NY

11 Broadway St.Suite 615 New York, NY 10004

Super Lawyers®

1

Updated: 11/17/2023

Overview

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...

Qualifications

Bar Admissions

  • New York
  • New Jersey
  • District of Columbia
  • U.S. Court of Appeals 2nd 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 District of New Jersey

Other Affiliations

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

Classes and Seminars

  • 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

Past Positions

  • New York City Office of Administrative Trials and Hearings, Judicial Law Clerk, - 2005

Education

  • New York University School of Law, New York, New York, 2007
    LL.M.
  • New York Law School, New York, New York, 2006
    J.D.
    Honors: magna cum laude
    Honors: Professor Albert Kalter Graduation Award for Excellence in Tax Law
    Honors: Dr. Max Reich Graduation Award for Excellence in Civil Trial Advocacy
    Honors: New York Law School Dean's Scholarship
    Honors: Moot Court Executive Board Member
  • New York University, 1999
    B.F.A.

Ancillary Businesses

  • 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)
  • 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
  • Speaker, Paycheck Protection Program Loan Fraud, 4th Annual Criminal Tax Day, New England, May 28, 2021
  • 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
  • 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
  • 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 2019May 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
  • 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;
  • 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;
  • 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.
  • Panelist, “Foreign Trusts and Trust like Structures,” 2022 Tax Institute (Virtual Event), hosted by the USC Gould School of Law, January 26, 2022
  • 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)

Fees

Accepts Credit Cards

Articles

Published Works

  • "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

Office Information

Address

11 Broadway St.Suite 615 New York, NY 10004

Fax

  • 312-549-9991

Achievements

Other Sources of Feedback About Zhanna A. Ziering

Included on the 2023 New York Metro list


Past Lists

  • 2017 New York Metro Super Lawyers list
  • 2016 New York Metro Super Lawyers list
  • 2015 New York Metro Super Lawyers list
  • 2014 New York Metro Super Lawyers list
  • 2013 New York Metro Super Lawyers list

View the profile for Zhanna A. Ziering on Super Lawyers

Honors

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

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