Scott Michel Comments on Enforcement of Offshore Accounts

Tax Notes

According to a piece by Lee Sheppard of Tax Notes, there have been indications that the IRS might want to declare victory against personal offshore accounts and go home. That time may have come, as the discussion at the recent OffshoreAlert conference in Miami Beach demonstrated.

The agency has shifted focus from punishment to targeted deterrence. So the government is going after a lot of people who are involved but who are not Americans with offshore accounts holding legal-source funds. The government is pursuing enablers like foreign bankers, relationship managers, accountants, lawyers, insurance agents, and also U.S. professionals.

“They seem to be mining the data from the Swiss bank program and data from other sources, and following various useful leads, rather than having a large dragnet seeking to sweep in dozens and dozens of account holders at a particular bank,” said Scott Michel of Caplin & Drysdale, Chtd., whose firm defends taxpayers and banks.

“Now, I think, the focus is on finding good cases that send specific messages, based on the Swiss bank program and other leads, whistleblowers, and cooperators. So actions against leavers, against U.S. and foreign professionals, continuing examination of foreign bankers and other enablers — all of these are tangents, but important tangents,” said Michel.

For the full article, please visit Tax Notes’ website (subscription required).

Excerpt taken from the article “Getting Offshore Accounts the Hard Way” by Lee A. Sheppard for Tax Notes.


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