Skip to Main Content

Tax Notes Quotes Scott Michel: Non-Willfulness Not Only Streamlined Filing Claim U.S. DOJ Checking

October 31, 2016, Tax Notes

According to the head of the Tax Division of the U.S. Justice Department, DOJ continues to review submissions by Swiss banks participating in the DOJ’s Swiss Bank Program, and other sources of data, looking for evidence that U.S. taxpayers may have provided false information during an IRS offshore disclosure.

While interviewing Caroline Ciraolo, the Tax Division’s Principal Deputy Attorney General, at a conference sponsored by the Association Section of Taxation, conference co-chair Scott D. Michel of Caplin & Drysdale referenced DOJ’s prior comments about how they were following up on streamlined disclosures, and Ms. Ciraolo confirmed that DOJ was reviewing whether taxpayers may have submitted false “non-willful” certifications and other disclosure-related documents, including expatriation forms, to ascertain whether they may have somehow abused the IRS’s offshore disclosure procedures.  For the full article, please visit Tax Notes’ website (subscription required).

Excerpt taken from the article “Non-Willfulness Not Only Streamlined Filing Claim U.S. DOJ Checking” by Nathan J. Richman for Tax Notes. 


About Caplin & Drysdale
Celebrating our 55th Anniversary in 2019, Caplin & Drysdale continues to be a leading provider of 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:
For more information, please visit us at
Washington, DC Office:
One Thomas Circle NW
Suite 1100
Washington, DC 20005
New York, NY Office:
295 Madison Avenue
12th Floor
New York, NY 10017


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.
©2021 Caplin & Drysdale, Chartered
All Rights Reserved.

Related Professionals

Related Practice Area(s)