Daily Tax Report Quotes Scott Michel on the American Bar Association's OVDP Webinar
Excerpt taken from the article.
Panelist Michel, a member of Caplin & Drysdale, said he agrees that there is "a body of evidence as to what the IRS thinks is willful. The absence of guidance is what it is, but there is plenty of guidance."
Caplin's Michel described the Justice Department's ongoing work in Switzerland, where many banks have entered a quasi-voluntary disclosure program to turn over information on account holders to the U.S. Michel said due to current constraints on the information that can be provided, "Swiss bank secrecy still exists," but is increasingly limited in scope.