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Bloomberg's International Tax Monitor Quotes Scott Michel: IRS Expands Relief for Disclosure, Tightens Rules for Neglect

June 18, 2014, International Tax Monitor

Bloomberg's International Tax Monitor quotes Scott D. Michel concerning the IRS's expansion of streamlined procedures to help taxpayers who were not intentionally evading taxes. Alternatively, The IRS is increasing penalties for certain taxpayers who have accounts at Banks that may be subject to IRS or DOJ investigations or other proceedings.  For the complete article, please click on the above link to view a PDF.

Excerpt taken from the article.

Scott Michel, a member of Caplin & Drysdale  in Washington, said, "My first impression is really quite positive" and said the expansion of the program to nonresidents offers a valuable path back into compliance. "This is a vehicle for a large number of people to fix their problems, Michel told Bloomberg BNA.

He said taxpayers should be cautious in asserting that their noncompliance wasn't willful and should carefully consult with their advisers before doing so, noting that the IRS has been "pretty aggressive" in its determinations of non-willful transgressions.

Michel said the increase of the OVDP penalty to 50 percent if a bank or facilitator is under investigation was something that many were expecting and said now is the time to come forward. "There are a lot of people waiting to see what happens with their banks. It's a real gamble to delay in situations where your bank could end up on the news," he told Bloomberg BNA.

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