Carolyn A. Schenck

Ms. Schenck joins Caplin & Drysdale as an accomplished senior government leader with almost 20 years of experience directing high-impact enforcement, compliance and litigation programs at the IRS, and partnering extensively with the Department of Justice on major financial fraud initiatives and cases.  She is nationally recognized for her deep expertise in tax controversy, civil fraud, digital assets, and matters involving complex financial crimes, and she brings a unique blend of litigation and policy experience to the firm. 

As the IRS’s first-ever National Fraud Counsel, Ms. Schenck played a pivotal role in establishing the position and teams of specialists, and she partnered closely with the newly-created Office of Fraud Enforcement – the first of its kind – to build a revitalized national program focused on civil and criminal tax fraud, advising on the design and execution of Service-wide initiatives to detect and deter fraud. She worked across all IRS operating divisions to develop and implement fraud enforcement strategies, notably redesigning the IRS’s criminal fraud referral process, civil fraud lead sheets, and role of IRS Counsel and fraud enforcement advisors. Ms. Schenck’s leadership shaped national strategies addressing Bank Secrecy Act violations, CARES Act fraud, employee retention credit issues, abusive insurance and land valuation schemes, high net worth non-filers, global high wealth, and digital asset compliance.

While serving as the Senior Level Counsel (Offshore), Ms. Schenck spearheaded the IRS’s efforts to combat offshore tax evasion. She led a IRS Counsel team to advise the Commissioner’s Offshore Compliance Initiative, oversaw 60+ John Doe summons actions involving banks, digital assets, offshore service providers, wealth advisors and other entities, and worked closely with DOJ on the Swiss Bank Program and multiple offshore prosecutions. Ms. Schenck coordinated and managed all offshore tax, foreign information return penalty matters, and FBAR matters under the IRS’s Litigation & Advisory (L&A) Division and coordinated all efforts with DOJ’s civil and criminal sections, while also serving as counsel to the Offshore Voluntary Disclosure Program, IRS-Criminal Investigation’s Voluntary Disclosure Practice, and Streamlined Filing Procedures. She also stood up IRS Counsel’s Digital Assets Cadre and led Counsel’s Fraud, Offshore and FBAR Cadres.

Throughout her government service, Ms. Schenck gained significant trial and litigation experience, managing hundreds of cases and litigating extensively before the U.S. Tax Court. She assisted DOJ on criminal tax prosecutions, injunctions, summons enforcement, refund suits, penalty cases, and actions against abusive tax return preparers and promoters. Ms. Schenck partnered with hundreds of IRS revenue agents and officers on complex legal, factual and other sensitive investigations, many of which spanned the globe, and is known for distilling technical legal and financial issues into practical, actionable solutions and defendable positions.  She also worked closely with the IRS Whistleblower Office on some of the most significant whistleblower matters the IRS has encountered. 

Ms. Schenck has been a dedicated educator, training thousands of government attorneys, law enforcement agents, IRS appeals officers, and IRS personnel on investigations, trial practice, substantive legal issues, and criminal prosecutions. She has been invited to share her expertise with the FBI’s money laundering squad and is a frequent speaker for professional and media audiences on enforcement trends, litigation strategy, and financial integrity. Ms. Schenck served as a go-to expert for hundreds of IRS-CI special agents, IRS personnel and government attorneys during her tenure and has authored thousands of pages of training materials. 

Before joining the IRS, Ms. Schenck served as an Attorney for the Securities and Exchange Commission, Division of Enforcement.  She also worked for Chief Judge Alex Kozinski of the Ninth Circuit and Chief Judge H. Robert Mayer of the Federal Circuit Courts of Appeals. She taught Honors Appellate Advocacy as an Adjunct Professor at Pepperdine University School of Law.  Earlier in her career, Ms. Schenck worked for U.S. Senator John McCain and as a weapons analyst.

Ms. Schenck earned her J.D. from Pepperdine University School of Law, where she was a member of the Pepperdine Law Review and the National Association of Administrative Law Judges Journal.

Bar & Court Admissions

• California
• Maryland (inactive)
• U.S. Supreme Court
• U.S. Tax Court
• Not a member of the DC Bar. Practicing under the direct supervision of a DC Bar member.

Education

J.D., Pepperdine University School of Law, 2003, Pepperdine Law Review

B.S., Northern Arizona University, 1997, summa cum laude

Clerkships

• Extern, Honorable Alex Kozinski of the U.S. Court of Appeals for the Ninth Circuit
• Extern, Honorable Robert H. Mayer of the U.S. Court of Appeals for the Federal Circuit

Honors & Recognitions

• IRS SB/SE Commissioner’s Award – Outstanding Award for Abusive Tax Fraud Case
• S. Department of Treasury – Outstanding Litigation Award for Abusive Tax Shelter Fraud Trial
• IRS Chief Counsel Award – Outstanding Contribution Team Award on Fraud Strategies for Abusive Tax Shelter
• IRS Chief Counsel Trial Advocacy Lucite Award – Outstanding Litigation Award for Fraud Trial
• Special IRS COVID Fraud Enforcement Award
• IRS LB&I Commissioner’s Award
• S. Department of Treasury Leadership Legacy Honors Award of Excellence
• IRS Commissioner Award
• Department of Justice Tax Division Special Contribution Award
• IRS Chief Counsel Trial Advocacy Lucite Award – Outstanding Litigation Award for Collection Due Process Trial
• IRS Chief Counsel Trial Awards (numerous)