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Scott Michel Quoted in WSJ Regarding German Investigation of Credit Suisse Clients with Offshore Insurance Structures

July 11, 2012, The Wall Street Journal
Excerpt taken from the article.

BERLIN--German tax inspectors in recent weeks have been raiding the homes of Credit Suisse Group AG clients suspected of evading taxes, according to bank and German government officials.

The investigation is centering on about 5,000 clients who between 2005 and 2009 allegedly bought insurance policies at a Bermuda-based subsidiary of the Swiss bank.

The policies were sold to clients as a way of earning tax-free interest on savings, people familiar with the investigation said. A Credit Suisse spokesman said in a statement the bank has told clients who bought the policies to talk to their tax advisers. He added that Credit Suisse told its clients they were responsible for determining their tax obligations when they bought the products, which the spokesman said were legal in Switzerland.

Scott Michel, an attorney with Caplin & Drysdale in Washington, said the IRS has been questioning U.S. taxpayers in its limited amnesty program about offshore insurance policies. The agency recently clarified that these policies must be reported as offshore accounts, with omissions possibly resulting in severe penalties.

Click here to read the entire article on the tax probe of Credit Suisse Group AG clients suspected of evading taxes via offshore insurance structures.
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