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Scott Michel Quoted in Tax Notes, IRS Submits Treaty Request to Switzerland on Credit Suisse Data

August 13, 2012, Tax Notes
Excerpt taken from the article.

The IRS on July 9 submitted a new, reformulated treaty request to the Swiss Federal Tax Administration (FTA) for information on U.S. taxpayers suspected of hiding undeclared assets and income in Swiss bank Credit Suisse, according to Swiss media reports.

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The IRS subsequently reformulated the request by providing a more detailed description of the manner in which the bank and clients concealed U.S. income and assets, according to an August 3 report in the Swiss newspaper Neue Zurcher Zeitung. The report says the FTA directed Credit Suisse to inform affected clients by July 31 that their information is subject to disclosure under a treaty request made by U.S. authorities. The new request affects fewer than 100 U.S. clients, the report says.

"What appears to have happened now is that the U.S. seems to have issued a narrower and more detailed request that seeks to overcome the objections on which the Swiss federal court decision was based," Scott D. Michel of Caplin & Drysdale told Tax Analysts. He said clients notified by Credit Suisse will have a right to file an objection, the account holder will be able to file an appeal with the Federal Administrative Court. Michel noted that account holders who are U.S. taxpayers should keep in mind the requirement to provide the U.S. attorney general with a copy of their objections.

Click on the above PDF to read the full article on the new IRS treaty request.
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