Not sure if this is good news, bad news, or just business as usual. Here’s the press release (hat tip as always to TaxProf Blog):
Today, President Barack Obama announced his intent to nominate Elizabeth Ann Copeland as a Judge to the United States Tax Court.
“Elizabeth has demonstrated unwavering integrity and dedication throughout her career,” said President Obama. “I am proud to nominate her to serve on the United States Tax Court.”
Her employer Strasburger & Price describes her:
Elizabeth A. Copeland is Board Certified in Tax Law by the Texas Board of Legal Specialization and focuses her practice on civil tax controversies. She has expertise handling offshore voluntary disclosure matters, employment tax disputes, tax collection matters, innocent spouse representations, IRS Appeals and Tax Court litigation.
Copeland made the following comment to the San Antonio Business Journal in March 2011. I don’t find this comment particularly encouraging, but in fairness she said these words well before people had become aware of the disastrous and unfair effects of the 2011 OVDI on U.S. persons in other countries who paid taxes and kept bank accounts where they lived, and owed little or no U.S. tax despite their paperwork omissions; none of Copeland’s fellow practitioners interviewed for that article mentioned Americans abroad either:
Because there is a large budget deficit, the government is emboldened by the success of the first Offshore Voluntary Compliance Program, and the government wishes to combat international tax evasion. The government also wants to be fair to those of us who timely file our tax returns and pay our tax. As stated by IRS Commissioner Doug Shulman, “the goal is to get people back into the U.S. tax system.”
If a taxpayer has a foreign account that should have been disclosed to the U.S. government, contact a local tax attorney familiar with the OVCI or program that can guide them through the criminal and civil aspects of the program. Because certain taxpayers will not qualify for the program (e.g. those under audit or investigation) it is best to consult an attorney.
Here is a presentation Copeland made (jointly with Jack Townsend, the author of the Federal Tax Crimes blog) about FBAR, OVDI, and FATCA in August 2011, notable as an early example of practitioners discussing the possibility of opting out of the “offshore” disclosure meat-grinder. Other than that, I’m not able to find more recent material in which Copeland has spoken about this whole mess, and the available materials don’t reveal very much about whether her opinions have evolved over the past four years.
