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Scott Michel Quoted in Reuters, U.S. Readies Papers V. Swiss Banks on Tax Evasion
Caplin & Drysdale

Scott Michel Quoted in Reuters, U.S. Readies Papers V. Swiss Banks on Tax Evasion

Date: 9/10/2011

Excerpt taken from article.

The United States is drafting legal documents that seek to force nearly a dozen Swiss banks and international banks with Swiss branches to disclose the identities of American clients evading billions of dollars in taxes, sources briefed on the matter said.

The drafting of the documents -- grand jury subpoenas and broad requests known as John Doe summonses -- is a fresh U.S. shot across the bow at Switzerland and its battered tradition of bank secrecy.

The Alpine country, a noted tax haven that is the global capital of offshore private banking, has been under attack from U.S. Justice Department and Internal Revenue Service officials conducting a broad criminal investigation into private banking services that U.S. authorities say enabled wealthy Americans to evade billions of dollars in taxes.

The documents could be served within a month or so on 10 banks, including some with headquarters outside Switzerland, these persons said.

James Cole, the deputy attorney general and the second-highest ranking law enforcement official in the United States, wrote to Switzerland's top tax negotiator, Michael Ambuehl, in a three-page letter dated August 31 that federal authorities intended to serve the documents.

"It's a fairly major event that the deputy attorney general would fire this off," said Scott Michel, a tax lawyer at Caplin & Drysdale in Washington. U.S. officials, who have confirmed the existence of the letter, are angry that it became public.

To read more about the ongoing U.S. investigation of Swiss banks, click here.

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