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Bloomberg's International Tax Monitor Quotes Scott Michel: Time Extensions Welcome Under Non-Prosecution Program

June 6, 2014, International Tax Monitor

Scott D. Michel was quoted by the International Tax Monitor regarding the DOJ's June 5 guidance on the Swiss Bank Program.  For the complete article, please click on the above link to view a PDF.

Excerpt taken from the article. 

With that June 30 deadline approaching, the extensions are "most welcome," Scott Michel, a member of Caplin & Drysdale Chartered in Washington, said. "There's a herculean effort on both sides of the Atlantic to try to achieve as much penalty mitigation as possible."

Michel said that the demand that every relationship manager has to be identified is a difficult one to meet. "Some of these banks have 150,000 accounts," he said. "But the Tax Division took its position that it wants every name and so be it."

He told Bloomberg BNA that the non-prosecution program is "creating a bit of an employee relations issue in the Swiss banking community."

Michel and Skarlatos also said the non-prosecution program for banks is likely to generate more takers for the individual OVDP.


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