• Criminal tax fraud investigations
• Sensitive civil tax examinations where fraud or substantial penalty issues may arise
• Voluntary disclosures
• Criminal and civil tax disputes with DC and various states
• Corporate internal investigations of tax and financial related matters
• Tax shelter matters, including criminal and civil penalty examinations of tax shelter promoters and professionals
• Advising US citizens living abroad about coming into tax compliance

Highlights

Mr. Michel is internationally recognized for his extensive experience in handling matters arising from the U.S. government's recent crackdown on undeclared foreign accounts, including criminal tax investigations, sensitive civil audits and voluntary disclosures. Such matters encompass a broad range of fact patterns, such as inherited accounts, situations that raise issues of complex undisclosed corporate or foundation structures, and unfiled Treasury “FBAR” forms. He is currently representing numerous clients worldwide in audits and investigations arising from IRS and Justice Department investigations involving UBS, HSBC and other banks, as well as voluntary disclosures throughout the U.S. involving dozens of foreign financial institutions throughout the world. (Click here for Mr. Michel's recent comments regarding this increasingly active area of tax enforcement.)

Professional Activities

Mr. Michel has made frequent appearances throughout the U.S., and in Singapore, Hong Kong, Zurich and Geneva, Switzerland, for presentations on voluntary disclosures and IRS enforcement regarding foreign accounts to multiple law firms, bankers, and tax and financial advisors, including presentations before the National University of Singapore, the Tax Academy of Singapore, Hong Kong University, and the Swiss-American Chamber of Commerce. He has also appeared at programs of the American Bar Association, The Tax Executives Institute (U.S. and foreign branches), The National Association of Criminal Defense Lawyers, and the Virginia, NYU, Tennessee and North Carolina Tax Institutes.

He is a Fellow of the American College of Tax Counsel, and is active in Bar groups in the tax controversy field:

• Former Chair of the ABA Tax Section’s Committee on Civil and Criminal Tax Penalties and current Vice-Chair for Legal Developments for this Committee
• Current Chair of the Standards of Tax Practice Committee
• Co-Chair of the Subcommittee on Tax Fraud, ABA White Collar Crime Committee 

He is also a co-founder and Director of Buildable Hours, Inc., a Washington, D.C. non-profit group that coordinates contributions and volunteer activities between law firms nationwide and local Habitat for Humanity organizations.

Awards and Honors

• Ranked as a Top Lawyer in the 2010 edition of Chambers USA: Band 2 in Tax Fraud – Nationwide; Band 4 in Tax Controversy – District of Columbia
• Listed in The Best Lawyers in America in the specialties of Criminal Defense: White-Collar and Tax Law (2006-2010) as well as in Super Lawyers (2007, 2008 and 2009)
• Ranked as a leading lawyer in Tax Controversy in the 2010 edition of The Legal 500
• AV rated by Martindale-Hubbell

Selected Recent Publications

Mr. Michel has written and lectured extensively on topics relating to criminal tax enforcement. He has also been quoted extensively in the media, including by The Wall Street Journal, The New York Times, Bloomberg, The Miami Herald, FoxNews, ABC News, and press outlets in Switzerland, France, Germany and the UK. His more recent articles include*:

• Undeclared Foreign Accounts—Voluntary Disclosures and FBARs After the IRS Settlement Initiative, Journal of Tax Practice and Procedure (December 2009 – January 2010)
• Voluntary Disclosure Becomes a Necessity, International Tax Review (May 2008)  
• Tax Crimes: Has the Bright Line Moved?, Law Journal Newsletters (with Justin A. Thornton, February 2008) 
• Criminal Tax Investigations and Current Year Returns: New Thoughts on a Perennial Issue, Andrews Litigation Reporter (v. 19, issue 3, December 2004) 
• Corporate Tax Departments and the New Focus on Corporate Criminality, The Tax Executive (November-December 2003) 
• Advising A Client With Secret Offshore Accounts - Current Filing And Reporting Problems, Journal of Taxation (September 1999) 

*For a comprehensive selection of Mr. Michel's articles, please click here. For a list of his media mentions (including the latest developments in the UBS settlement issue), please click here.