Skip to Main Content
 

Scott Michel Comments on IRS Spontaneous Disclosures

October 12, 2017, Tax Notes
The IRS Criminal Investigation division is reconsidering the strategic placement of its foreign-posted attachés in light of the changing global financial landscape, a division official said October 11.

. . .

The attachés are all normally trained CI special agents and are strategically located to assist with investigations done in the United States, as well as to liaise with foreign government partners, said [Eric Hylton, the newly minted deputy chief at CI]. In addition to interacting with and providing training to foreign tax agencies and tracking fugitives, the attachés deal with spontaneous disclosures, “in which individuals are saying, ‘We have seen this particular activity [and] it may be of interest to the U.S.,’” he said. CI has seen a significant number of spontaneous disclosures, he said.

Scott D. Michel of Caplin & Drysdale, Chtd. said many clients and practitioners have questioned just how often spontaneous disclosures actually occur [and asked Hylton if spontaneous disclosures were becoming more frequent, and Hylton agreed, noting that CI was receiving information from counterparts all over the world.]

To view the full article, please visit Tax Notes' website (subscription required).

Excerpt taken from the article "IRS Criminal Investigation Reconsidering Where to Post Attachés" by Nathan J. Richman for Tax Notes.

________________________________________________

About Caplin & Drysdale
Having celebrated our 50th Anniversary in 2014, Caplin & Drysdale continues to be a leading provider of tax, tax controversy, and litigation legal services to corporations, individuals, and nonprofits throughout the United States and around the world. We are also privileged to serve as legal advisors to accounting firms, financial institutions, law firms, and other professional services organizations.

The firm's reputation over the years has earned us the trust and respect of clients, industry peers, and government agencies. Moreover, clients rely on our broad knowledge of the law and our keen insights into their business concerns and personal interests. Our lawyers' strong tactical and problem-solving skills - combined with substantial experience handling a variety of complex, high stakes, matters in a boutique environment - make us one the nation's most distinctive law firms.

With offices in New York City and Washington, D.C., Caplin & Drysdale's core practice areas include:

-Bankruptcy
-Business, Investment & Transactional Tax
-Complex Litigation
-Corporate Law
-Employee Benefits
-Exempt Organizations
-International Tax
-Political Law
-Private Client
-Tax Controversies
-Tax Litigation
-White Collar Defense

For more information, please visit us at www.caplindrysdale.com.

Washington, DC Office:
One Thomas Circle, NW
Suite 1100
Washington, DC 20005
202.862.5000
        New York, NY Office:
600 Lexington Avenue
21st Floor 
New York, NY 10022
212.379.6000

___________________________

Disclaimer
This communication does not provide legal advice, nor does it create an attorney-client relationship with you or any other reader. If you require legal guidance in any specific situation, you should engage a qualified lawyer for that purpose. Prior results do not guarantee a similar outcome.

Attorney Advertising
It is possible that under the laws, rules, or regulations of certain jurisdictions, this may be construed as an advertisement or solicitation.

© 2017 Caplin & Drysdale, Chartered
All Rights Reserved.