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Bloomberg BNA Quotes Scott Michel Regarding Tax Evasion

May 10, 2013, Bloomberg BNA

Scott D. Michel talks with Bloomberg BNA regarding the U.S., U.K. and Austrailia teaming up to battle international tax evasion.

Reproduced with permission from Daily Tax Report, 91 DTR GG-1 (May 10, 2013). Copyright 2013 by The Bureau of National Affairs, Inc. (800-372-1033) <>. Excerpt taken from article.

"This reflects a significant widening of the net by the U.S. in attempting to find unreported offshore assets and accounts," Scott Michel, president of Caplin & Drysdale in Washington, told BNA May 9.

Caplin's Michel said May 9 that it has been known for some time that as-yet unreported funds and assets have been moving away from countries that have been more prominently targeted by IRS, such as Switzerland and Liechtenstein.

Those assets have been headed to such jurisdictions as Singapore and Hong Kong, he said.

"This announcement obviously reflects the view by the U.S. and its partners that there are still a substantial number of people who have not yet come forward to make voluntary disclosures, and that by information sharing with some of our most reliable partners the U.S. can make greater, and more visible inroad into countries that have not yet been the focus of the offshore enforcement efforts of the last five years," Michel said.

He stressed that "it should go without saying" that anyone who might get caught in the government's net should consider entering the United States' voluntary disclosure program. "The combination of criminal prosecution and civil money penalties for anyone whose names get turned over before they try to do so can obviously be catastrophic," Michel cautioned.

The Caplin practitioner said the agreement announced May 9 will enable Australia, the United States, and the U.K. to bypass more cumbersome mechanisms for information sharing and allow for more spontaneous disclosures and similar expedited transfers of information among the three nations.

"This will likely expedite the flow of data and make it possible for the IRS and the Tax Division of the Justice Department to move more quickly not just against account holders, but against banks, bankers, fiduciaries, and other persons and entities thought to be ‘enablers' of tax evasion and fraud," Michel said.

He said it was interesting that IRS did not mention the Joint International Tax Shelter Information Center, which comprises the three nations mentioned in the news release plus Canada.

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