Mark Matthews Comments on Value of DOJ's Non-Target Letters

Tax Notes spoke with Caplin & Drysdale's Mark E. Matthews concerning the potential value of non-target letters available to institutions in categories 3 and 4 of the Justice Department's Swiss bank program.  For the full article, please visit Tax Notes’ website (subscription required).

Excerpt taken from the article "Despite Less Certainty, Swiss Bank Non-Target Letters Valuable" by Nathan J. Richman for Tax Notes.

Some have questioned the value of the non-target letters available to banks in categories 3 and 4. For example, Mark E. Matthews of Caplin & Drysdale Chtd. said that DOJ non-target letters provide little formal protection because of common exceptions for newly discovered facts or if the bank provides false information. "It is really more of a Good Housekeeping seal of approval," he said, adding that the professional costs of obtaining the letters may outweigh their value in many situations.