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Tax Notes Today Quotes Scott Michel on Enforcement Efforts Turning Toward 'Leavers'

August 5, 2015, Tax Notes Today
Tax Notes Today quoted Scott D. Michel on the government using information collected through the IRS's offshore voluntary disclosure program and the DOJ's Swiss bank program to investigate "leavers," or individuals who moved funds from one unreported offshore account to another. For the complete article, please visit Tax Notes Today's website (subscription required).

Excerpt taken from the article "Enforcement Efforts Turning Toward 'Leavers'" by Nathan J. Richman for Tax Notes Today.

Scott D. Michel of Caplin & Drysdale Chtd. said, "The Justice Department's [Swiss] bank program has, as one of its primary focuses, the disclosure of information concerning the movement of funds out of Switzerland over the period beginning in August 2008 to the present."

Michel said there are indications that CI has followed up on voluntary disclosures "where you have a fact pattern of the closure of an account in Switzerland and the movement of funds into the custody of a Singapore asset manager." Michel said this was the first his firm had seen of an investigation into one of the leavers.


Michel also said that he has seen an increase in Caribbean inquiries and that informed speculation placed significant leaver funds in Israel, Singapore, and Hong Kong.


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