Bloomberg Quotes Scott Michel: IRS Boosts Pressure for Disclosure of Offshore Accounts
Bloomberg News quoted Scott D. Michel concerning the increased penalties for U.S. account holders at Swiss banks as to whom a Justice Department, IRS or related proceeding may become public. After August 4, such account holders may face a 50% penalty as the price for an offshore voluntary disclosure. This is particularly the case for account holders at Swiss banks currently under investigation or "Category 2" banks participating in the DOJ Swiss Bank program. For the complete article, please visit Bloomberg's website.
Excerpt from the article.
Tax attorney Scott Michel said "it's inevitable" that the 106 Swiss banks will sign non-prosecution agreements and hand over data, leading to U.S. treaty requests.
"If you're a non-compliant taxpayer who's been sitting on the sidelines and you had money at the 106 banks after August 2008, the risk calculus has now changed," said Michel of Caplin& Drysdale. "Before today, your risk in that circumstance was pretty diffuse."