Scott Michel Explores Ethical Considerations When Fixing Past Mistakes at NYU Institute on Federal Taxation 

For clients who have willfully failed to comply with tax or tax-related obligations relating to foreign income or foreign assets, a voluntary disclosure may be a means to resolve non-compliance and limit exposure to criminal prosecution. This panel will discuss the ethical responsibilities for tax professionals, including maintaining confidentiality, avoiding conflicts of interest, and the overarching rules of Circular 230, that come into play when advising clients about the pros and cons of voluntary disclosures and other corrective options to consider when addressing omissions and errors in complying with tax obligations.