Scott Michel Comments on IRS Spontaneous Disclosures

Tax Notes
The IRS Criminal Investigation division is reconsidering the strategic placement of its foreign-posted attachés in light of the changing global financial landscape, a division official said October 11.

. . .

The attachés are all normally trained CI special agents and are strategically located to assist with investigations done in the United States, as well as to liaise with foreign government partners, said [Eric Hylton, the newly minted deputy chief at CI]. In addition to interacting with and providing training to foreign tax agencies and tracking fugitives, the attachés deal with spontaneous disclosures, “in which individuals are saying, ‘We have seen this particular activity [and] it may be of interest to the U.S.,’” he said. CI has seen a significant number of spontaneous disclosures, he said.

Scott D. Michel of Caplin & Drysdale, Chtd. said many clients and practitioners have questioned just how often spontaneous disclosures actually occur [and asked Hylton if spontaneous disclosures were becoming more frequent, and Hylton agreed, noting that CI was receiving information from counterparts all over the world.]

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Excerpt taken from the article "IRS Criminal Investigation Reconsidering Where to Post Attachés" by Nathan J. Richman for Tax Notes.


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