Scott D. Michel is a Member of Caplin & Drysdale who brings nearly four decades of experience in complex and sensitive tax controversy matters to his work on behalf of firm clients. With the firm since 1981, Mr. Michel served for many years on Caplin & Drysdale’s Board of Directors, and was the firm's President from 2007-2015.
Services
Mr. Michel’s practice centers on tax enforcement and controversy, with an emphasis on highly-sensitive criminal tax, and potential criminal tax issues. These cases range from handling complex grand jury investigations to tax and related crimes, advising in sensitive civil tax examinations, and assisting wealthy individuals and families address unintentional U.S. tax compliance errors. With corporate and individual clients spanning five continents, Mr. Michel has particularly extensive experience managing U.S. compliance and enforcement issues arising from international and offshore circumstances. In specific, his practice encompasses the following types of cases:
- Counseling financial institutions and other companies, advisors and professionals, and individual taxpayers on criminal tax matters arising from criminal tax investigations conducted by the U.S. Justice Department Tax Division and the Internal Revenue Service Criminal Investigation Division.
- Advising on highly-sensitive civil tax examinations of individuals or companies where potential fraud issues may arise.
- Assisting clients in IRS offshore-related tax examinations seeking to impose tax, interest and penalties for the prior failure to report foreign accounts or assets.
- Working with international families, that have complex financial footprints in the U.S. and other countries, on addressing U.S. tax compliance issues.
- Helping to bring into compliance U.S. individual and corporate taxpayers worldwide who have tax reporting failures in prior years, whether intentional or accidental.
- Participating in corporate internal investigations of tax and finance-related matters.
- Handling tax shelter matters, including criminal and civil penalty examinations of tax shelter promoters and professionals.
- Providing sensitive advice on ethical issues to tax practitioners.
- Advising in non-tax white collar and “inside the Beltway” cases raising sensitive, high-profile issues.
Representative Engagements
- Helping families, individuals and companies come into U.S. compliance by correcting prior year filings. In most of these cases, the risk of criminal prosecution was eliminated and the cases resolved often for significant savings in tax and penalty amounts. Many such cases have arisen because of the failure of the U.S. taxpayer to report foreign accounts or other substantial offshore assets, while others raise U.S.-centric tax issues where an individual, a family or a business needed to correct material errors on prior tax returns.
- Handling sensitive offshore-related civil examinations for businesses, advisors, high-net-worth families, athletes, and others residing around the world, often working in the background behind civil practitioners. A number of these cases were resolved quietly and confidentially for a fraction of the amounts initially sought by the IRS.
- Acting as criminal tax counsel for entrepreneurs, business owners and companies under criminal investigation by the IRS or DOJ. Such investigations range from U.S.-related tax problems, such as the underreporting of income, the claiming of improper deductions, and payroll tax issues, to complex international structures involving foreign trusts or corporations that raise issues of unreported foreign assets, income and delinquent filings. Many of these cases resulted in non-public decisions by the U.S. government not to bring criminal charges.
- Resolving cases for a number of banks and other financial services firms with the U.S. Department of Justice Tax Division arising from their business in handling U.S. taxpayer accounts. These representations usually resulted in non-prosecution agreements between the institution and the DOJ, or no action taken.
- Advising tax professionals and professional services firms on sensitive and ethical practice-related issues.
Professional Activities
Mr. Michel served as the Vice-Chair for Committee Operations of the American Bar Association Section of Taxation from 2016-2018, having previously served as a Section Council Director and as the Chair of the Section's Committees on Civil and Criminal Tax Penalties and the Standards of Tax Practice. He is also an Adjunct Professor of Law at the University of Miami School of Law Graduate Program in Taxation, the Regent for the Federal Circuit for the American College of Tax Counsel, and a member of the International Fiscal Association (IFA).
Mr. Michel also served as a Mentor in the American Bar Association Rule of Law Initiative (ROLI), advising government officials responsible for tax enforcement in the Croatian Ministry of Finance. For his work in this regard, and that of his colleagues Cono Namorato and Mark Matthews, Caplin & Drysdale received the 2018 Pro Bono Award from ROLI. Mr. Michel previously performed a similar role in connection with ROLI’s predecessor organization in Poland in 1992.
He is also a co-founder and Director of Buildable Hours, Inc., a Washington, D.C., nonprofit group that coordinates contributions and volunteer activities between law firms nationwide and local Habitat for Humanity organizations.
Recent News
Mr. Michel has been quoted extensively in the media, including by The Wall Street Journal, The New York Times, Bloomberg, The Miami Herald, CNN, FoxNews, ABC News, and press outlets in Switzerland, France, Germany and the UK. Recent media coverage includes:
- Tax Notes Quotes Scott Michel on Tax Conspiracy Cases, Tax Notes, August 28, 2020
- Caplin & Drysdale Earns Top Ranking in 2021 "Best Lawyers in America", U.S. News & World Report, August 20, 2020
- 17 Caplin & Drysdale Attorneys Recognized in 2020 Legal 500 Ranking, The Legal 500, July 6, 2020
- Chambers USA Recognizes Caplin & Drysdale Attorneys, May 5, 2020
- Caplin & Drysdale D.C. Attorneys are Recognized by Super Lawyers®, Super Lawyers, May 4, 2020
- Law360 Quotes Scott Michel on Enforcement of a Potential Wealth Tax, Law360 Tax Authority, September 12, 2019
- Scott Michel Talks About the State of Offshore Enforcement, Law360, August 22, 2019
- Caplin & Drysdale Attorneys Listed as "Best Lawyers In America", August 15, 2019
- Scott Michel Comments on Justice Stevens in Law360, Law360, July 18, 2019
- The Legal 500 Recognizes 19 Caplin & Drysdale Attorneys, The Legal 500, June 4, 2019
- Scott Michel Talks to Tax Notes on Offshore Enforcement, Tax Notes, April 29, 2019
- Caplin & Drysdale Attorneys Recognized Once Again by Chambers USA, Chambers USA, April 25, 2019
- Super Lawyers® Recognizes 22 Caplin & Drysdale Attorneys in D.C., Super Lawyers, April 22, 2019
- CNN Quotes Scott Michel and Meghan Biss on Tax Impact of College Admissions Scandal, CNN, March 22, 2019
- Wall Street Journal Quotes Scott Michel on Manafort Sentencing, The Wall Street Journal, March 8, 2019
- 10 Caplin & Drysdale Attorneys Contribute to ABA's Annual Section of Taxation Midyear Meeting, January 3, 2019
- Scott Michel Discusses Offshore Voluntary Disclosure Program Shutdown with Law360, Law360, September 28, 2018
- Scott Michel Talks to Tax Notes on Nominee to Head IRS, Tax Notes, August 28, 2018
- Caplin & Drysdale Improves Ranking in 2019 "Best Lawyers in America", August 15, 2018
- POLITICO Quotes Scott Michel on Manafort Criminal Tax Charges, POLITICO, August 15, 2018
- Caplin & Drysdale International Tax Controversy Team Receives ABA Pro Bono Award, Caplin & Drysdale, Chartered, August 2, 2018
- 2018 Legal 500 Distinguishes 18 Caplin & Drysdale Attorneys, Firm Renews "Top-Tier Firm" Ranking for Tax Controversy, The Legal 500, May 31, 2018
- 9 Caplin & Drysdale Attorneys Contribute to ABA's Annual Section of Taxation Meeting, Caplin & Drysdale, May 9, 2018
- Chambers USA Recognizes 10 Caplin & Drysdale Lawyers as "Leaders in Their Fields", Chambers USA, May 3, 2018
- 18 Caplin & Drysdale Attorneys Recognized by Super Lawyers in D.C., April 23, 2018
- Caplin & Drysdale Attorneys Support Rettig as IRS Commissioner, Tax Notes, April 19, 2018
- Scott Michel Talks to Law360 on IRS Replacing Offshore Voluntary Disclosure Program, Law360, April 10, 2018
- Scott Michel Comments on Closure of IRS Offshore Voluntary Disclosure Program, MLex US Tax Watch, March 23, 2018
- Scott Michel Comments on Charles Rettig, Nominee to Head IRS, MLex US Tax Watch, March 2, 2018
- Scott Michel Comments on Charles Rettig's Nomination for IRS Commissioner, Tax Notes, February 9, 2018
- Scott Michel Comments on Money Laundering Bill's Use in Tax Cases, Tax Notes, January 2, 2018
- Caplin & Drysdale Tax Lawyers Work with Croatian Ministry of Finance on Tax Enforcement Issues, December 11, 2017
- New York Times Quotes Scott Michel on Tax Plan's Ambiguity, The New York Times, December 5, 2017
- Law360 Quotes Scott Michel: ‘Willfulness' in Civil FBAR Cases Comes Down to the Facts, Law360, November 21, 2017
- Scott Michel Comments on FBAR Penalty Examinations, Bloomberg BNA Daily Tax Report, November 7, 2017
- Scott Michel Speaks With U.S. Tax Court Chief Judge on Increased Global Tax Litigation at ITEC Session, Bloomberg BNA, October 30, 2017
- Scott Michel and Chief Judge Paige Marvel Discuss Increase in International Tax Enforcement Cases at Tax Controversy Conference, Tax Notes, October 30, 2017
- Tax Notes Quotes 3 Caplin Tax Controversy Attorneys on the IRS's Aggressive FBAR Enforcement, Tax Notes, October 19, 2017
- Scott Michel Comments on High-Profile Foreign Bank Account Decision, Tax Notes, October 12, 2017
- Scott Michel Comments on IRS Spontaneous Disclosures, Tax Notes, October 12, 2017
- Scott Michel Comments on Public Leaks Aiding in U.S. OVDP Penalty, Tax Notes, August 18, 2017
- Caplin & Drysdale Earns Top Ranking in 2018 "Best Lawyers in America", August 15, 2017
- 18 Caplin & Drysdale Lawyers Recognized in 2017 Legal 500 Ranking, The Legal 500, June 2, 2017
- Caplin & Drysdale Lawyers Improve Their 2017 Chambers' Rankings, Chambers USA, June 2, 2017
- Scott Michel Comments on Enforcement of Offshore Accounts, Tax Notes, May 15, 2017
- Caplin & Drysdale Lawyers Listed Among D.C.'s Most Prominent Practitioners, Super Lawyers, April 27, 2017
- Scott Michel Comments on Border Adjustment Treaty Damage Hindering Tax Enforcement, Tax Notes, March 2, 2017
- Caplin & Drysdale Attorneys Mentor ABA Rule of Law Initiative Fellows from Croatia, February 27, 2017
- Scott Michel Speaks to Tax Notes on Tax Practitioners' Obligations When Advising Clients with Foreign Accounts, Tax Notes, January 17, 2017
- BNA Quotes Scott Michel: Will Trump Keep Spotlight on Multinationals' Tax Compliance?, Bloomberg BNA, January 13, 2017
- Scott Michel Leads Discussion of Offshore Issues at Criminal Tax Conference, Tax Notes, December 12, 2016
- Tax Notes Quotes Scott Michel: DOJ Seeks John Doe Summons on Largest U.S. Bitcoin Exchanger, Tax Notes, November 22, 2016
- Tax Notes Quotes Scott Michel: Non-Willfulness Not Only Streamlined Filing Claim U.S. DOJ Checking, Tax Notes, October 31, 2016
- Daily Tax Report Quotes Scott Michel: IRS Goes Beyond Switzerland in Offshore Tax Enforcement Efforts, Daily Tax Report, October 28, 2016
- Bloomberg BNA Interviews Scott Michel on Increased IRS/DOJ Offshore Compliance Efforts, Bloomberg BNA, October 21, 2016
- Tax Notes Quotes Scott Michel on IRS Adding 47 Facilitators to Increased OVDP Penalty List, Tax Notes, October 18, 2016
- Bloomberg Interviews Scott Michel: Finish Line Unclear for Some FATCA Pacts as Banks Worry, Bloomberg BNA, September 23, 2016
- Scott Michel Comments on Donald Trump's Tax Returns in The Street, The Street, August 29, 2016
- ACAMS Money Laundering Quotes Scott Michel on Possible Additional Required Disclosures in the UK, ACAMS Money Laundering, August 25, 2016
- Bloomberg Quotes Scott Michel on Restaurateur Rowen Seibel, Bloomberg BNA, August 19, 2016
- Best Lawyers in America Lists 18 Caplin & Drysdale Attorneys, U.S. News & World Report, August 15, 2016
- Bloomberg Quotes Scott Michel on Donald Trump's Tax Returns, Bloomberg, August 12, 2016
- The New Yorker Interviews Scott Michel on Trump's Tax-Returns, The New Yorker, August 10, 2016
- Tax Analysts Quotes Mark Matthews and Scott Michel on the Future of OVDP, Tax Analysts, August 1, 2016
- Scott Michel Discusses the Lack of Americans Named in Panama Papers with The American Lawyer, The American Lawyer, July 29, 2016
- Scott Michel Comments on TIGTA Recent Report Criticizing OVDP, Tax Notes, June 22, 2016
- Caplin & Drysdale Recognized for Cutting Edge Advice, The Legal 500, June 16, 2016
- Caplin & Drysdale Listed Among Top Lawyers for Tax, Bankruptcy, Estate Planning and Political Law, Chambers USA, June 1, 2016
- Scott Michel and Mark Matthews Comment on Number of U.S. Taxpayers Exposed by Panama Papers, Tax Notes, May 10, 2016
- Tax Notes Quotes Scott Michel on Criminal Tax Enforcement, Tax Notes, May 10, 2016
- Daily Tax Report Quotes Scott Michel on Panama Papers Database, Daily Tax Report, May 9, 2016
- Super Lawyers Recognizes Caplin & Drysdale Lawyers from Several Practice Areas, Super Lawyers, April 26, 2016
- European Union News Quotes Scott Michel on Efforts to Challenge View that U.S. is a Tax Haven, European Union News, April 11, 2016
- NBC Quotes Scott Michel on Panama Papers, NBC News, April 5, 2016
- Scott Michel Comments on the U.S. as a Tax Haven for the Wealthy, Channel One Russian TV, April 5, 2016
- WSJ Talks to Scott Michel After Two Firms Plead Guilty to Helping U.S. Clients Hide Millions in Offshore Accounts, Wall Street Journal, March 9, 2016
- Scott Michel Comments on DOJ's Latest Offshore Efforts Focusing on UBS Accounts in Singapore, Tax notes, March 7, 2016
- Scott Michel Comments on Attorney Confidentiality FATCA Exemption, Daily Tax Report, March 1, 2016
- Financial Planning Journal Quotes Scott Michel on U.S. Becoming the World's Favorite New Tax Haven, Financial Planning Journal, February 16, 2016
- Scott Michel Comments on U.S. Becoming the World's Favorite New Tax Haven, Bloomberg Businessweek, January 27, 2016
- Bloomberg BNA Quotes Scott Michel on How a Global Push to Combat Tax Evasion Led to an Influx of Information, Bloomberg BNA, January 12, 2016
- Scott Michel Comments on the Trends in IRS Criminal Enforcement, Tax Notes, December 21, 2015
- Scott Michel Discusses U.S. Non-Prosecution Agreements Not Protecting Related Companies, Tax Notes, December 14, 2015
- Washingtonian Names Caplin & Drysdale Attorneys Among Washington's Top Lawyers, November 19, 2015
- Scott Michel Comments on Disclosure of Singapore and Israeli Bank Information re U.S. Accountholders, Bloomberg BNA's White Collar Crime Report, October 9, 2015
- Tax Notes Today Quotes Scott Michel on Enforcement Efforts Turning Toward 'Leavers', Tax Notes Today, August 5, 2015
- The American Lawyer Names Caplin & Drysdale Global Legal Award Recipient for Swiss Tax Investigations, The American Lawyer, July 31, 2015
- Wall Street Journal Quotes Scott Michel on IRS's Probe of Singapore Firm, The Wall Street Journal, July 19, 2015
- Caplin & Drysdale Named Top Tier Firm for Tax Controversy, June 8, 2015
- Bloomberg BNA Quotes Scott Michel on New FBAR Penalty Limits and Eighth Amendment Litigation, Tax Analysts, June 5, 2015
- Tax Analysts Speaks to Scott Michel: FBAR Penalty Guidance Reflects Sensitivity to U.S. Constitutional Concerns, Tax Analysts, June 2, 2015
- Clients and Peers Distinguish Caplin & Drysdale in Chambers' Rankings, Chambers USA, May 19, 2015
- Scott Michel Comments on Taxpayers Seeking Entry To OVDP, Bloomberg BNA, May 12, 2015
- Scott Michel Comments on U.S. Caterpillar Criminal Tax Inquiry, Worldwide Tax Daily, May 8, 2015
- Scott Michel Featured on Nightly Business Report's Whistleblower Series, CNBC, May 7, 2015
- Scott Michel Comments on the End of Offshore Bank Secrecy, CNBC, April 30, 2015
- Scott Michel Discusses Tax Crime Penalties and Remedies, The Washington Post Magazine, April 27, 2015
- Super Lawyers Lists Caplin & Drysdale Lawyers, Caplin & Drysdale, April 23, 2015
- Caplin & Drysdale's White Collar Defense Practice Earns Recognition, Corporate LiveWire, April 9, 2015
- Scott Michel Comments on War on Tax Cheats, The Hill, April 8, 2015
- Scott Michel Comments on Impact of First Swiss Bank to Settle Under U.S. Tax Program, Thomson Reuters, March 30, 2015
- The Daily Tax Report Quotes Scott Michel: Swiss Bank Agrees to Pay U.S. $211 Million to Avoid Prosecution for Aiding Tax Evasion, Daily Tax Report, March 30, 2015
- WSJ Talks to Scott Michel About Tax Fraud, The Wall Street Journal, March 13, 2015
- CNN Quotes Scott Michel on the Taxation of American Minors Living Abroad, CNN Money, March 11, 2015
- Daily Tax Report Quotes Scott Michel on the American Bar Association's OVDP Webinar, Daily Tax Report, February 24, 2015
- Scott Michel Comments on Offshore Enforcement Issues Regarding HSBC and UBS, LAW360, February 13, 2015
- International Tax Monitor Quotes Scott Michel: Obama Proposal to Require FATCA Reporting to Account Holders, Bloomberg BNA, February 3, 2015
- WSJ Quotes Scott Michel on $400 Million Bank Leumi Settlement, The Wall Street Journal, January 2, 2015
- Scott Michel Comments on U.S. Strengthening International Tax Enforcement Efforts, Worldwide Tax Daily, November 7, 2014
- CNBC Quotes Scott Michel: Tax Dodgers Should Not Be Heartened by This Verdict, CNBC, November 4, 2014
- On the Eve of IFA-Mumbai, Bloomberg Interviews Scott Michel and David Rosenbloom: FATCA Strengthens U.S. Tax Enforcement Hand in India, Daily Tax Report and International Tax Monitor, October 8, 2014
- Scott Michel Comments on Questions Surrounding Standards of Willful Conduct Under Streamlined Version of OVDP, Daily Tax Report, September 18, 2014
- Scott Michel Offers Insights on The DOJ's Swiss Bank Program and Coming Enforcement, Le Temps, September 16, 2014
- CNBC Quotes Scott Michel: Tough Tax Rules See Expats Ditch Their U.S. Passports, CNBC, September 11, 2014
- Caplin & Drysdale Lawyers Earn Best Lawyers Ranking, August 21, 2014
- With Its Founders, Caplin & Drysdale Celebrates 50 Years of Excellence, Caplin & Drysdale, July 23, 2014
- Clients and Peers Recommend Caplin & Drysdale in 2014 Legal 500 Ranking, The Legal 500, July 1, 2014
- Wall Street Journal Quotes Scott Michel on the Hazards of Offshore-Account Disclosure, The Wall Street Journal, June 27, 2014
- Bloomberg BNA Quotes Scott Michel on Streamlined Penalty Structure Available to Those in OVDP, Bloomberg BNA, June 24, 2014
- Worldwide Tax Daily Quotes Scott Michel on Updated OVDP, Worldwide Tax Daily, June 23, 2014
- Bloomberg Quotes Scott Michel: IRS Boosts Pressure for Disclosure of Offshore Accounts, Bloomberg News, June 19, 2014
- Bloomberg's International Tax Monitor Quotes Scott Michel: IRS Expands Relief for Disclosure, Tightens Rules for Neglect, International Tax Monitor, June 18, 2014
- Bloomberg's International Tax Monitor Quotes Scott Michel: Time Extensions Welcome Under Non-Prosecution Program, International Tax Monitor, June 6, 2014
- Daily Tax Report Quotes Scott Michel on New Offshore Disclosure Program for U.S. Taxpayers, Daily Tax Report, June 4, 2014
- Caplin & Drysdale Earns Top Honors in 2014 Chambers USA, Chambers USA, May 28, 2014
- Daily Tax Report Quotes Scott Michel on the Departure of DOJ Tax Division Chief Keneally, Bloomberg, May 27, 2014
- Swiss TV Interviews Scott Michel on Implications of Credit Suisse Plea, RTS Radio Television Suisse, May 20, 2014
- The Washington Post Lists Caplin & Drysdale Attorneys Among the Top Attorneys in D.C., The Washington Post, April 30, 2014
- CCTV America Interviews Scott Michel on FATCA's Role in Improving Global Tax System, CCTV America, April 25, 2014
- The Wall Street Journal Quotes Scott Michel: New Risks for Advisers with Clients Who Own Unreported Overseas Assets, The Wall Street Journal, April 21, 2014
- Tax Notes Today Quotes Scott Michel: DOJ Doesn't See Barriers to Receipt of Information Under Swiss Bank Program, Tax Notes Today, March 19, 2014
- Scott Michel Comments on the Credit Suisse Senate Hearing, Bloomberg News, February 26, 2014
- Bloomberg Quotes Scott Michel and Mark Matthews: Swiss Banks Under Pressure as Deadline Nears for DOJ Program to Find U.S. Accounts, Bloomberg, December 20, 2013
- Tax Directors Handbook Recommends Caplin & Drysdale As A Leading Tax Law Firm, Tax Directors Handbook, December 19, 2013
- POLITICO Quotes Scott Michel: Swiss Banks Urge U.S. Tax Dodgers to Come Clean to Beat Deadline, POLITICO, December 17, 2013
- Washingtonian Recognizes Caplin & Drysdale Attorneys Among Washington's Best Lawyers, Washingtonian Magazine, December 3, 2013
- WSJ Interviews Scott Michel on U.S. Government Seeking Information from U.S. Banks, The Wall Street Journal, November 15, 2013
- NYTimes Quotes Scott Michel: Bank Records Sought in Offshore Tax Inquiry, The New York Times, November 12, 2013
- Scott Michel Speaks with Swiss TV Regarding John Doe Summons and ZKB, ECO, November 11, 2013
- Bloomberg Quotes Scott Michel Regarding IDR Response Deadlines, Bloomberg, November 7, 2013
- Worldwide Tax Daily Quotes Scott Michel: Swiss Court Orders Banks to Give Ex-Employees Copies of Data Shared With U.S., Worldwide Tax Daily, November 4, 2013
- Wall Street Journal Quotes Scott Michel: More U.S. Taxpayers Admit to Secret Swiss Accounts, The Wall Street Journal, November 1, 2013
- DOJ Deal with Swiss Banks Impacts U.S. Taxpayers and Financial Firms Around the World, Caplin & Drysdale, October 31, 2013
- 19 Caplin & Drysdale Attorneys Achieve Best Lawyers in America Ranking, U.S. News & World Report, October 21, 2013
- Worldwide Tax Daily Quotes Scott Michel: Swiss Bank Ends Operations, Citing U.S.-Swiss Tax Dispute, Worldwide Tax Daily, October 21, 2013
- Tax Notes Quotes Scott Michel: IRS Auditors Take Closer Look at 'Quiet' Disclosures of Offshore Accounts, Tax Notes, October 18, 2013
- Tax Notes Today Quotes Scott Michel: Swiss Bankers Voice Concerns Over DOJ Compliance Program, Tax Notes Today, October 11, 2013
- CNN Money Quotes Scott Michel: Americans Turn In Passports As New Tax Law Hits, CNN Money, September 5, 2013
- Reuters Quotes Scott Michel on U.S. – Swiss Bank Deal, Reuters, September 3, 2013
- Mark Matthews, Scott Michel and Cono Namorato Comment On U.S.-Swiss Tax Agreement, Thomson Reuters, International Taxes Weekly, August 30, 2013
- Scott Michel Speaks with German Radio Regarding U.S.-Swiss Tax Deal, SRF Radio, August 30, 2013
- Scott Michel Speaks with Bloomberg on DOJ's Tax Deal with Swiss Banks to Reveal U.S. Account Information, Bloomberg BNA's Daily Tax Report, August 30, 2013
- U.S.-Swiss Tax Deal Impacts U.S. Account Holders and Dozens of Swiss Financial Institutions, Caplin & Drysdale, August 29, 2013
- South China Morning Post Quotes Scott Michel: Tax Evaders Feel the Heat in Havens, South China Morning Post, August 24, 2013
- The Wall Street Journal Quotes Scott Michel: As U.S. Expats Balk at Tax Law, Asia Sees a Shift, The Wall Street Journal, August 12, 2013
- Scott Michel Talks to Tax Notes About FBAR Compliance, Tax Notes, August 5, 2013
- Reuters Quotes Scott Michel: U.S., Liechtenstein Bank Reach Settlement in Tax Evasion Case, Reuters, July 31, 2013
- The Wall Street Journal Quotes Scott Michel on Efforts to Identify Norwegian Tax Evaders, The Wall Street Journal, July 30, 2013
- Scott Michel Speaks to Swiss Radio: Swiss Finance Minister Proposes Permits for Swiss Banks to Hand Over Data to U.S., World Radio Switzerland, July 4, 2013
- Scott Michel Speaks to Tax Notes: Swiss Court Blocks Credit Suisse From Sharing Ex-Employee's Data With U.S., Tax Notes, July 1, 2013
- The Wall Street Journal Quotes Scott Michel: Swiss Parliament Pushes Back on U.S. Banks Deal, The Wall Street Journal, June 18, 2013
- Scott Michel Speaks in Kuwait City at FATCA Seminar, June 18, 2013
- Caplin & Drysdale Comments on ICIJ's Offshore Leaks Database, Caplin & Drysdale, June 17, 2013
- Scott Michel Quoted Regarding U.S. Finding Jurisdiction for Foreign Bank Prosecutions, Tax Notes, June 10, 2013
- Scott Michel and Michael Pfeifer Selected for Legal Tax Advisory Board, June 10, 2013
- Scott Michel and David Rosenbloom Quoted on Recent U.S. Efforts to Tackle Offshore Tax Evasion, Tax Notes, June 10, 2013
- The Legal 500 Recommends Caplin & Drysdale As a Leading Firm For 2013, The Legal 500, June 3, 2013
- 14 Caplin & Drysdale Attorneys Recognized in Chambers USA 2013, Chambers USA, May 29, 2013
- Scott Michel Comments on Actions of Swiss Government to Authorize Banks to Disclose Information, New York Times, May 29, 2013
- The Wall Street Journal Quotes Scott Michel: Swiss Bow to Pressure for More Bank Data, The Wall Street Journal, May 29, 2013
- Scott Michel Quoted by Tax Notes on Impact of IRS Scandal, Tax Notes, May 17, 2013
- Scott Michel and David Rosenbloom Quoted On the Impact of Offshore Tax Evasion, CardHub.com, May 10, 2013
- Bloomberg BNA Quotes Scott Michel Regarding Tax Evasion, Bloomberg BNA, May 10, 2013
- Wealthy Americans Target of New IRS Initiative, Caplin & Drysdale, May 7, 2013
- Scott Michel and David Rosenbloom Cited in Canadian Report on Tax Evasion, Canadian House of Commons - Report on the Standing Committee on Finance, May 1, 2013
- Scott Michel is Quoted on U.S. Efforts to Combat Offshore Tax Evaders, Fox Business, May 1, 2013
- Super Lawyers Lists Nineteen Caplin & Drysdale Attorneys, Super Lawyers, April 29, 2013
- The Fiscal Times Quotes Charles Ruchelman on Why More Affluent Americans Pay No Taxes, The Fiscal Times, April 11, 2013
- Scott Michel Talks to The Wall Street Journal About Hiding Offshore Accounts From Advisers, The Wall Street Journal, April 11, 2013
- The Wall Street Journal Quotes Scott Michel: Tax Havens Shift as Luxembourg Loosens Bank Secrecy, The Wall Street Journal, April 10, 2013
- CCTV America Talks With Scott Michel About Offshore Bank Account Inquiries, CCTV America, April 10, 2013
- The Wall Street Journal Quotes Scott Michel: Luxembourg to Reveal Bank Data, The Wall Street Journal, April 10, 2013
- Scott Michel Talks to Tax Notes, U.S. Requests Liechtenstein Data, Tax Notes, March 26, 2013
- Scott Michel and David Rosenbloom Comment on Americans with Asian Bank Accounts, Bloomberg, March 25, 2013
- PODCAST: IRS Targeting Tax Havens in Singapore and Hong Kong, Accounting Today, March 12, 2013
- Scott Michel Quoted in The Wall Street Journal, A Dip Into Swiss Secrecy Rules, The Wall Street Journal, February 22, 2013
- WSJ Quotes Scott Michel on U.S. Crackdown of Offshore Tax Evasion, January 31, 2013
- Tax Notes Names Scott Michel Among the Top 10 in Tax Community for 2012, January 9, 2013
- NPR Talks to Scott Michel About Implications of Wegelin Guilty Plea, January 8, 2013
- Scott Michel Interviewed by Geneva's "Le Temps" Regarding Wegelin Guilty Plea, January 7, 2013
- Chris Rizek and Scott Michel Comment on Wegelin Guilty Plea, January 6, 2013
- Scott Michel and Mark Matthews Join American Citizens Abroad, December 26, 2012
- Scott Michel Quoted in Tax Notes, Whistleblower Referrals Leading to CI, DOJ Investigations, Tax Notes, November 19, 2012
- Scott Michel Discusses Plea Agreement of former UBS banker Christos Bagios, Tax Notes, November 12, 2012
- Scott Michel Quoted in the Wall Street Journal on Expatriate Foreign Bank Accounts, Wall Street Journal, October 19, 2012
- Caplin & Drysdale Announces Expansion of Tax Practice and Relocation of New York Office, September 20, 2012
- Scott Michel Quoted in Epoch Times, Swiss Banks Stand to Lose Hundreds of Billions, Epoch Times, September 17, 2012
- Scott Michel Quoted in Tax Notes, IRS Submits Treaty Request to Switzerland on Credit Suisse Data, Tax Notes, August 13, 2012
- Scott Michel Quoted in Reuters, Update 1-US Treasury Tells How to Comply With Offshore Account Law, Reuters, July 26, 2012
- Scott Michel Quoted in WSJ Regarding German Investigation of Credit Suisse Clients with Offshore Insurance Structures, The Wall Street Journal, July 11, 2012
- Scott Michel Comments on New IRS Voluntary Disclosure Guidance, Tax Notes, July 2, 2012
- Scott Michel Comments on New Voluntary Disclosure Guidance From the IRS, Reuters, June 29, 2012
- Scott Michel Quoted in Tax Notes, IRS Revising FAQ for Offshore Voluntary Disclosure Program, Tax Analysts, June 25, 2012
- Scott Michel Quoted in Reuters, U.S. in Tax Crackdown Pact With Swiss, Japanese, Reuters, June 21, 2012
- Scott Michel Quoted on CNBC, Tax Shelters: Why Israel Could Be the Next Switzerland, CNBC, June 19, 2012
- Chambers and Legal 500 Recognize Caplin & Drysdale in 2012 Top Rankings, Chambers USA / The Legal 500, June 12, 2012
- Scott Michel Quoted in The Wall Street Journal, IRS Suffers Setback in Identifying Secret Credit Suisse Accounts, The Wall Street Journal, April 12, 2012
- Scott Michel Quoted on Swissinfo.ch, No Let-Up in US Fight Against Tax Evasion, swissinfo.ch, April 4, 2012
- Scott Michel Quoted in Forbes, The Biggest Story in Banking, Thanks to IRS, Forbes, March 21, 2012
- Scott Michel Quoted in Wall Street Journal Article, Swiss Amend U.S. Tax Treaty, Wall Street Journal, March 6, 2012
- Scott Michel Quoted in Reuters, U.S. Enlists 5 EU Nations in Offshore Tax Crackdown, Reuters, February 8, 2012
- Scott Michel Quoted in Bloomberg BNA, Wegelin Indictment Signals New Battleground in U.S. Offshore Evasion Fight, Bloomberg BNA Daily Tax Report, February 6, 2012
- World Radio Switzerland Interviews Scott Michel, After Wegelin Bank's Indictment, Who's Next?, World Radio Switzerland, February 6, 2012
- Scott Michel Quoted in Swiss Radio and Swiss Info, U.S. Indicts the Oldest Swiss Private Bank, Swiss Radio, February 3, 2012
- Scott Michel Comments on Voluntary Disclosure Penalty Issues, Toronto Star, January 11, 2012
- Scott Michel Quoted in Reuters, Swiss Case Lifts Curtain on Correspondent Banking, Reuters, January 6, 2012
- Scott D. Michel Comments in Tax Notes Today Article, IRS to Allow Extensions of August 31 OVDI Application Deadline, Tax Analysts-Tax Notes Today, January 3, 2012
- The Washingtonian Lists Eight Caplin & Drysdale Attorneys as Top Lawyers in Washington, Washingtonian Magazine, December 30, 2011
- Scott Michel Quoted in Swiss Article, US Tax "Ultimatum" Has Swiss Banks Sweating, Swissinfo.ch, December 21, 2011
- Scott Michel Quoted in Reuters, Taxpayers With Overseas Accounts Seethe at Penalties, Reuters, December 8, 2011
- Scott Michel Comments in Reuters, Credit Suisse Will Disclose Names of U.S. Clients, Reuters, November 8, 2011
- Scott Michel Comments in The Wall Street Journal, Credit Suisse to Name Names, The Wall Street Journal, November 8, 2011
- Bloomberg Law Interview: Scott Michel Says Financial Firms Are Struggling to Comply With FATCA, Bloomberg Law, September 29, 2011
- Scott Michel Quoted in Financial Post, IRS Strikes a Conciliatory Tone Toward Canadians, Financial Post, September 28, 2011
- Scott Michel Quoted in Reuters, U.S. Readies Papers V. Swiss Banks on Tax Evasion, Reuters, September 10, 2011
- Scott Michel Comments on the IRS Amnesty for Undeclared Offshore Account Holders, Bloomberg, September 7, 2011
- Scott Michel Quoted in Swissinfo, Banks Say U.S. Tax Deal Must Respect Swiss Law, swissinfo, September 5, 2011
- The Best Lawyers in America Ranks 19 Caplin & Drysdale Attorneys as Leaders in Their Field, U.S. News & World Report, September 1, 2011
- Scott Michel Comments in CNBC and The Wall Street Journal About IRS Crackdown of Undeclared Offshore Accounts, CNBC, Wall Street Journal, August 19, 2011
- Scott Michel Quoted in Tax Analysts, Practitioners Assess Offshore Initiative as Deadline Approaches, Tax Notes, August 15, 2011
- Scott Michel Quoted in Bloomberg, Credit Suisse Likely to Settle Criminal Tax Probe, Bloomberg, August 15, 2011
- Scott Michel Quoted in Swissinfo, Credit Suisse "Worse Off" Than UBS in the U.S., swissinfo.ch, July 27, 2011
- Scott Michel Comments on Possible U.S. Indictment of Swiss Bank Credit Suisse on Tax Evasion Charges, Reuters, July 15, 2011
- Scott Michel Comments in Reuters Article, "U.S. Senate Bill Targets Offshore Tax "Trickery", Reuters, July 12, 2011
- Chambers and Legal 500 Recognize Caplin & Drysdale in 2011 Top Rankings, Chambers USA / The Legal 500, June 16, 2011
- Caplin & Drysdale Taps Mark D. Allison to Bolster Tax Practices in New York, Caplin & Drysdale, June 16, 2011
- Scott Michel Comments in Bloomberg, Swiss in Talks With U.S. on Untaxed Assets, Official Says, Bloomberg, June 10, 2011
- Scott D. Michel Comments in Tax Notes Today Article, IRS to Allow Extensions of August 31 OVDI Application Deadline, Tax Analysts-Tax Notes Today, June 3, 2011
- Scott Michel Comments in Bloomberg, IRS Loosens Aug. 31 Deadline for Offshore Tax Disclosures, Bloomberg, June 3, 2011
- Scott Michel Comments on Verdict in Recent Tax Shelter Criminal Prosecution, New York Law Journal, May 26, 2011
- Americans Holding Money in Secret Offshore Accounts Risk Prosecution, NBC Universal, April 15, 2011
- Scott Michel Comments About Offshore Accounts and the End to Bank Secrecy, CNBC, April 15, 2011
- Scott Michel Comments on U.S. Crackdown of Undeclared Offshore Accounts, Bloomberg, March 11, 2011
- Scott Michel Comments on U.S. Indictments of Credit Suisse Employees, Swiss Info, February 27, 2011
- Scott Michel Comments on IRS's Second Amnesty Program for Undeclared Offshore Account Holders, The Wall Street Journal, Bloomberg, The New York Times, Automated Trader, Tax Analysts, South China Morning Post, February 23, 2011
- Caplin & Drysdale Attorneys Comment on WikiLeaks' Release of Offshore Account Data, The Wall Street Journal, World Radio Switzerland, The New York Times, Marketplace, February 3, 2011
- Caplin & Drysdale Promotes Four Attorneys to Membership in the Firm, Caplin & Drysdale, February 1, 2011
- WikiLeaks' Release of 2,000 Foreign Bank Accounts to Spell Tax Complications for Undeclared Account Holders, Caplin & Drysdale, January 17, 2011
- Scott Michel States Switzerland's Cantonal Banks Next Target of U.S. Tax Investigators, World Radio Switzerland, December 28, 2010
- Scott Michel Comments on Potential New Amnesty Program From IRS, Bloomberg Businessweek, December 9, 2010
- Scott Michel Comments on Israeli Bank's Response Amid IRS Scrutiny of Undeclared Offshore Accounts, Reuters, November 1, 2010
- Scott Michel Comments on IRS Scrutiny of Tax Attorneys, Financial Adviser, August 31, 2010
- Scott Michel Comments on U.S. Government's Investigation of Offshore Accounts, Tax Analysts, Eurasia Review, The Wall Street Journal, August 24, 2010
- 19 Caplin & Drysdale Attorneys Named Best Lawyers in America, U.S. News & World Report, August 4, 2010
- Scott Michel Comments on Swiss Approval of UBS Settlement With the U.S., Bloomberg, Schweizer Fernsehen, June 17, 2010
- Chambers USA and Legal 500 Recognize Caplin & Drysdale in 2010 Top Rankings, Chambers USA / The Legal 500, June 15, 2010
- Scott Michel Comments on Swiss-U.S. Deal on UBS, Forexyard, The New York Times, June 9, 2010
- Caplin & Drysdale Attorneys Comment on the End of the Era of Bank Secrecy, Forexyard, Bloomberg, PRLog, FA Magazine, etc., May 4, 2010
- IRS Unveils Criteria for Swiss Bank Account Disclosures, The Washington Post, November 17, 2009
- Scott Michel Comments on U.S. Targeting Hong Kong for Tax Evaders, Bloomberg, November 12, 2009
- Scott Michel Comments on the IRS Settlement Initiative and Implications after Amnesty Deadline, The New York Times, ABC News, The Wall Street Journal, Bloomberg, October 28, 2009
- Scott Michel Comments on IRS Crackdown of Undisclosed Offshore Accounts With UBS, Credit Suisse, Julius Baer, LGT, The Washington Post, Dow Jones, NPR, Bloomberg, CNBC, etc., September 22, 2009
- U.S. Justice Dept Says No Plans to Drop UBS Case, guardian.co.uk, June 23, 2009
- U.S. and Switzerland Agree to New Tax Treaty, Swiss Info, June 19, 2009
- Chambers USA 2009 Recognizes Eight Caplin & Drysdale Attorneys as ‘America's Leading Lawyers', Chambers USA, June 15, 2009
- Super Lawyers Recognizes Nine Caplin & Drysdale Attorneys in Five Practice Areas, Super Lawyers, March 27, 2009
- IRS Seduces Offshore Account Holders, Caplin & Drysdale, March 26, 2009
- Countries in Europe and Asia Agree to Modify Treaty Provisions: Profound Implications for Noncompliant U.S. Taxpayers With Foreign Accounts, Caplin & Drysdale, March 13, 2009
- IRS Wants to Force Swiss Bank UBS to Lift Veil of Secrecy, Miami Herald, February 20, 2009
- UBS Faces IRS Fight Over Names, International Herald Tribune, February 19, 2009
- UBS Faces IRS Fight Over Names, Shrs Rise on Deal, Interactive Investor, February 19, 2009
- U.S. Government Suing UBS to Get at Names of the Rich, The Financial Post, February 19, 2009
- U.S. Seeks More UBS Account Records in Tax Battle, Reuters, February 19, 2009
- Corporate Crime Defense Bar in Unison: More Prosecutions Are on the Way, Corporate Crime Reporter, February 19, 2009
Click here for a full list of media coverage.
Speaking Engagements
In his 38 years of practice, Mr. Michel has appeared multiple times throughout the world as a speaker and panelist on U.S. tax enforcement and controversy issues. Among other engagements, he has addressed the Swiss-American and Korean-American Chambers of Commerce; Joint US-IFA programs in Colombia and Barcelona; the National University of Singapore and the Tax Academy of Singapore; the Vienna University of Economics and Business; Hong Kong University and the Chinese University of Hong Kong; and audiences in Kuwait City and Dubai. He has also testified as an expert on offshore account enforcement before the Standing Committee on Finance of the Canada House of Commons.
In the U.S., Mr. Michel founded and served as co-chair of the ABA Section of Taxation's Annual International Tax Enforcement and Controversy Conference during 2014-2017. He has also appeared at other programs held by the ABA, 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. Recent presentations include:
- Panelist, Tax Compliance Matters, ALI CLE International Trust and Estate Planning 2020 Part 1, December 9, 2020
- Speaker, A Conversation with IRS Chief Don Fort – Criminal Tax Enforcement: Yesterday, Today, and Tomorrow, American Bar Association, September 23, 2020
- Faculty, Steering Committee, Cambridge Forum on International Tax Disputes, February 26, 2020
- Panelist, Ethics in Tax Practice, 15th Biennial Parker C. Fielder Oil and Gas Tax Conference, The University of Texas School of Law (Austin), November 22, 2019
- Panelist, Compliance Obligations and Planning Issues for U.S. Clients with Foreign Income and Investments, ALI CLE International Trust and Estate Planning, November 15, 2019
- Chair, Protecting Taxpayers Under Constitutional, EU, and International Human Rights Laws in an Era of Increased Regulation and Heightened Enforcement, 19th Annual U.S. and Europe Tax Practice Trends, April 4, 2019
- Moderator, Tax Avoidance v. Tax Evasion, Cambridge Forum on International Tax Disputes, February 28, 2019
- Moderator, The All New Two-Minute Drills, ABA Section of Taxation, 2019 ABA Midyear Meeting, January 18, 2019
- Panelist, Tax Transparency and Compliance, ALI CLE International Trust and Estate Planning, November 1, 2018
- Panelist, Penalties for Failure to Report Foreign Assets: The Difference Between a Huge Problem and an Innocent Oversight, 10th Annual Tax Controversy Forum, NYU School of Professional Studies, June 21, 2018
- Panelist, Are Human Rights Affected By Tax Information Reporting and Disclosures, ABA 2018 Paris Sessions, June 9, 2018
- Speaker, Ethical Consideration with International Clients, STEP Miami 9th Annual Summit, June 1, 2018
- Chair, Scott Michel Serves as Section Vice Chair at 2018 ABA Section of Taxation May Meeting, 2018 ABA Section of Taxation May Meeting, May 10, 2018
- Panelist, Ethics in Tax Controversy, TEI 2018 Audits & Appeals Seminar, May 1, 2018
- Panelist, Breakout Session D: Taking on a Criminal Tax Case? Don't Leave Home Without These Critical Practice Tips!, 32nd Annual National Institute on White Collar Crime, February 28, 2018
- Moderator, Plenary: Representing the Global Citizen, 34th Annual National Institute on Criminal Tax Fraud and Seventh Annual National Institute on Tax Controversy, December 8, 2017
- Panelist, AML and Tax, ABA/ABA Financial Crimes Enforcement Conference, December 4, 2017
- Panelist, Ethics, The George Washington University Law School and IRS, 30th Annual Institute on Current Issues in International Taxation, December 1, 2017
- Chair, 5th Annual International Tax Enforcement and Controversy Conference, American Bar Association Section of Taxation / Tax Executives Institute, October 27, 2017
- Panelist, From The Experts: IRS Representation Tools, Techniques, and Defensive Strategies—Civil and Criminal Tax Update, NYU 76th Institute on Federal Taxation, October 22, 2017
- Speaker, Part 2 of 7 Tax Audits and Litigation & Part 2 of 6 International Tax Lunch Series: International Tax Enforcement Update, D.C. Bar, October 11, 2017
- Speaker, Recent Audit and Controversy Experiences in Colombia and the U.S., USA Branch of International Fiscal Association, August 24, 2017
- Moderator, International Enforcement: What's Happening Next In The Battle Against Unreported Foreign Assets, 9th Annual Tax Controversy Forum, NYU School of Professional Studies, June 15, 2017
- Panelist, The Future of U.S. Cross-Border Criminal Tax Enforcement, Cross Border Planning for Private Clients, May 18, 2017
- U.S. Taxpayers - Why They Can Hide No Longer and What They Can Do Now, Cross Border Planning for the Private Client, May 15, 2017
- Speaker, Tax Enforcement: Where in the World Is the IRS Now, American Bar Association Criminal Justice Section, 31st Annual National Institute on While Collar Crime, March 8, 2017
- Speaker, FATCA and Panama Papers as Catalysts to More International Information Sharing, Cambridge Forums, November 11, 2016
- Speaker, Administration, Penalties and Tax Payer Rights – Power of Tax Authorities and Updates from Key Jurisdictions on New Trends, Developments and Legislative Changes, Cambridge Forums, November 10, 2016
- Panelist, From The Experts: IRS Representation Tools, Techniques And Defensive Strategies – Civil & Criminal Tax Update, NYU 75th Institute on Federal Taxation, October 23, 2016
- Speaker, Criminalization of Tax Planning, Including General Audit in Post-BEPS Environments and Practical Strategies for Minimizing Exposure, USA Branch of International Fiscal Association, September 23, 2016
- Moderator, Turning the Tables: The United States as a Tax Haven Destination, American Bar Association Section of Taxation 2016 May Meeting, May 7, 2016
- Speaker, The Criminalization of Tax Violations – A Negative Trend, American Bar Association Tax Section, International Fiscal Association-USA & Italy Branch, International Bar Association Tax Committee, and Tax Executives Institute Inc., March 17, 2016
- Speaker, Comprehensive Tax Enforcement: How The Government Is Using All Its Tools, American Bar Association Criminal Justice Section, 30th Annual National Institute on While Collar Crime, March 2, 2016
- Moderator, Offshore: Where in the World is Enforcement Now?, American Bar Association, 32nd Annual National Institute on Criminal Tax Fraud and 5th National Institute on Tax Controversy Conference, December 10, 2015
- Panelist, From the Experts: IRS Representation Tools, Techniques and Defensive Strategies - Civil & Criminal Tax Update, NYU 74th Institute on Federal Taxation, October 25, 2015
- Chair, 3rd Annual International Tax Enforcement Conference, 3rd Annual International Tax Enforcement Conference, October 16, 2015
- Moderator, Q&A with Assistant Attorney General, U.S. Department of Justice Tax Division, 3rd Annual International Tax Enforcement Conference, October 16, 2015
- Speaker, Ethics: Fixing Common Tax Problems, American Law Institute Continuing Legal Education (ALI CLE), Handling a Tax Controversy 2015: Current Trends in Civil Tax Controversies and Litigation, October 8, 2015
- The Making of Tax Policy in the U.S., The Chinese University of Hong Kong, Centre for Financial Regulation and Economic Development (CFRED), Tax Law Seminar, September 9, 2015
- Moderator, Offshore Enforcement 2015: Recent Developments and Hot Topics, Caplin & Drysdale, Chartered, September 1, 2015
- Speaker, Tax Enforcement and the Practitioner, 2015 State Bar of Texas Tax Section Annual Meeting, June 19, 2015
- Chair, 7th Annual Tax Controversy Forum, New York University School of Professional Studies, June 5, 2015
- Presenter, Answering Your Civil and Criminal Offshore Disclosure Questions, American Bar Association, Webinar, February 24, 2015
- Speaker, When the Company is the Target: Ethical and Other Issues, American Bar Association, 31st Annual National Institute on Criminal Tax Fraud & 4th Annual National Institute on Tax Controversy, December 11, 2014
- Panelist, Offshore Enforcement 2014: Recent Developments and Hot Topics, Caplin & Drysdale, Chartered, October 13, 2014
- Speaker, Offshore Compliance Update, STEP Los Angeles July Presentation and Working Lunch Meeting, July 10, 2014
- Moderator, U.S. Global Tax Enforcement Priorities, American Bar Association, June 24, 2014
- Moderator, The Offshore Voluntary Program: To Participate or Not Participate, That Is the Question, New York University School of Professioanl Studies, 6th Annual Tax Controversy Forum, June 20, 2014
- Chair, Transparency Comes to Tax Enforcement, American Bar Association, International Tax Enforcement Conference, March 18, 2014
- Chair, Ethical Issues Facing Tax Practitioners, American Law Institute (ALI) CLE, Hot Topics for Accountants & Tax Lawyers: Tax Returns, Advice, & Examination, December 16, 2013
- Scott Michel to Moderate Panel at ABA Criminal Tax Fraud and Tax Controversy Conference, December 12, 2013
- Scott Michel to Speak at University of Texas Annual Taxation Conference, December 4, 2013
- Speaker, From the Experts: Tax Controversy and Tax Litigation Update, New York University, 72nd Institute on Federal Taxation, November 17, 2013
- Speaker, From the Experts: Tax Controversy and Tax Litigation Update, New York University, 72nd Institute on Federal Taxation, October 20, 2013
- Speaker, Other FATCA Issues: IGAs, Participating FFI Agreements; Sponsored FFI Agreements, Form 8938; FBAR, American Law Institute (ALI) CLE, International Trust and Estate Planning, October 11, 2013
- Speaker, Developments in Offshore Tax Compliance (Practitioner View), American Law Institute (ALI) CLE, International Trust and Estate Planning, October 11, 2013
- Scott Michel to Speak at Swiss-American Chamber of Commerce Panel Meeting, September 26, 2013
- Scott Michel and David Rosenbloom to Speak at IFA Copenhagen 2013, August 26, 2013
- Scott Michel to Speak at FATCA Seminar in Kuwait City, June 17, 2013
- Chair, Enforcement & Criminal Tax Panel, Federal Bar Association, 37th Annual Tax Law Conference, March 1, 2013
- Scott Michel to Speak at ABA Criminal Tax Fraud and Tax Controversy 2012 Meeting, December 7, 2012
- Panelist, From the Experts: Tax Controversy and Tax Litigation Update, New York University, 71st Institute on Federal Taxation, November 11, 2012
- Scott D. Michel & H. David Rosenbloom to Speak at ABA Section of Taxation's Conference on International Tax Enforcement, November 8, 2012
- Scott Michel to Speak at Tulane Tax Institute, October 31, 2012
- Scott Michel to Speak at UCLA Extension 2012 Annual Tax Controversy Institute, October 17, 2012
- Speaker, Developments in Offshore Tax Compliance (Practitioner View), American Law Institute (ALI) CLE, 2012 International Trust and Estate Planning Course, August 24, 2012
- Scott Michel to Speak at the NYU 4th Annual Tax Controversy Forum, June 15, 2012
- Speaker, The Ethical Framework - Duties of the Tax Practitioner to the Client and to the System, University of Virginia Tax Foundation, 64th Annual Conference on Federal Taxation, June 7, 2012
- Speaker, Ask Tax Controversy Experts, American Institute of CPAs, Small Business Tax Practitioners Conference and AICPA Conference on Tax Controversy, May 3, 2012
- Speaker, Sensitive Issue Examinations, American Institute of CPAs, Small Business Tax Practitioners Conference and AICPA Conference on Tax Controversy, May 3, 2012
- Panelist, Civil and Criminal Tax Enforcement: What Can We Expect from the IRS?, J. Nelson Young Tax Institute, April 26, 2012
- Moderator, Foreign Assets: From Voluntary Disclosure to FATCA, 28th Annual National Institute on Criminal Tax Fraud and the First National Institute on Tax Controversy, March 2, 2012
- Scott Michel and Christopher Rizek to Speak at the Federal Bar Association's 36th Annual Tax Law Conference, March 2, 2012
- Panelist, Ethical Issues in International Tax Practice, The George Washington University Law School, 24th Annual Institute on Current Issues in International Taxation, December 15, 2011
- Panelist, From the Experts: Tax Controversy and Tax Litigation Update, New York University, 70th Institute on Federal Taxation, November 15, 2011
- Panelist, A Walk on the Wild Side - IRS Examination of Foreign Account Holders Who Did Not Participate in or Opted out of the Voluntary Disclosure Intitiatives, University of California Los Angeles (UCLA) Extension, 27th Annual Tax Controversy Institute, October 25, 2011
- Moderator, IRS Criminal Investigation Update and Voluntary Disclosures: Still Possible?, University of California Los Angeles (UCLA) Extension, 27th Annual Tax Controversy Institute, October 25, 2011
- Panelist, FBAR for the Fiduciary, DC Bar Tax Section, Estate Planning Committee, October 18, 2011
- Speaker, Recent Developments, IRS National Tax Forum, August 30, 2011
- Speaker, Developments in Offshore Tax Compliance (Practitioner View), American Law Institute (ALI) CLE, American Bar Association, 14th Annual Advanced Course of Study for Counselors to Foreign and U.S. Clients, August 19, 2011
- Chair, Standards of Tax Practice Committee, American Bar Association, 2011 Midyear Meeting, January 21, 2011
- Panelist, Ethical Issues in International Tax Practice, George Washington University & The Internal Revenue Service, 23rd Annual Institute on Current Issues in International Taxation, December 10, 2010
- Panelist, Obtaining and Use of Foreign Evidence at Trial, American Bar Association, 27th Annual National Institute on Criminal Tax Fraud, December 2, 2010
- Moderator, The Quiet Revolution - FATCA and Bank Secrecy, American Bar Association, 2010 Joint Fall CLE Meeting, September 25, 2010
- Chair, Standards of Tax Practice, American Bar Association, 2010 Joint Fall CLE Meeting, September 24, 2010
- Speaker, Developments in Offshore Tax Compliance (Practioner View), American Law Institute (ALI) CLE and American Bar Association, 13th Annual Advanced ALI-ABA Course of Study for Counselors to Foreign and U.S. Clients, August 20, 2010
- 13th Annual Advanced ALI-ABA Course of Study for Counselors to Foreign and U.S. Clients, August 19, 2010
- International Tax Issues Facing U.S. Taxpayers With Foreign Accounts and Their Financial Institutions, March 18, 2010
- Panelist, Emerging Issues in Whistleblower Claims, American Bar Association, 2010 Midyear Meeting, January 22, 2010
- Panelist, Emerging Ethical Issues in Whistleblower Claims, American Bar Association, 2010 Midyear Meeting, January 22, 2010
- Chair, Standards of Tax Practice Committee, American Bar Association, 2010 Midyear Meeting, January 22, 2010
- Speaker, Criminal Tax Fraud, American Bar Association, 26th Annual National Institute on Criminal Tax Fraud, December 3, 2009
- Brave New World of Tax Enforcement: UBS, International and Corporate Criminal Tax Issues, November 13, 2009
- Voluntary Disclosures: Still Possible After UBS?, October 27, 2009
- Undeclared Foreign Accounts, Trusts and Estates: Implications of IRS Enforcement Actions, July 16, 2009
Click here for a full list of speaking engagements.
Recent Publications
Mr. Michel has written extensively on topics relating to criminal tax enforcement. His more recent articles include:
- "INSIGHT: The 2020 Revision to the Internal Revenue Manual's Voluntary Disclosure Practice: More Consistency with Greater Risk,"
with Mark E. Matthews, Bloomberg Tax: Daily Tax Report, January 12, 2021
- "U.S. Tax Enforcement – A New Decade Begins,"
with Victor A. Jaramillo, IFC, November 5, 2020
- "The IRS Resumes its Global High-Wealth Examination Program and Targets High Income Non-Filers,"
with Dianne C. Mehany, Victor A. Jaramillo, Zhanna A. Ziering, and Mark E. Matthews, Caplin & Drysdale Client Alert, July 22, 2020
- "INSIGHT: The IRS's Renewed Focus on Fraud-Implications for Tax Practitioners,"
Bloomberg Law, May 8, 2020
- "Updated Filing and Payment Extensions Under Notice 2020-23,"
with Dianne C. Mehany, Victor A. Jaramillo, Zhanna A. Ziering, and Aaron M. Esman, Caplin & Drysdale Client Alert, April 10, 2020
- "Abatement of Foreign Pension Trust Penalties,"
with Dianne C. Mehany, Kirsten Burmester, and Victor A. Jaramillo, Caplin & Drysdale Client Alert, March 31, 2020
- "IRS Announces Tax Collection Easing and Payment Flexibility During COVID-19 Crisis,"
with Charles M. Ruchelman, Benjamin Z. Eisenstat, and Aaron M. Esman, Caplin & Drysdale Client Alert, March 30, 2020
- "Cryptocurrency Criminal Tax Cases Coming Soon,"
with Victor A. Jaramillo, Zhanna A. Ziering, and Mark E. Matthews, Caplin & Drysdale Client Alert, July 23, 2019
- "The New Voluntary Disclosure Practice: A Fair Compromise?,"
with Zhanna A. Ziering, Dianne C. Mehany, and Mark E. Matthews, Caplin & Drysdale Client Alert, December 3, 2018
- "IRS's Offshore Voluntary Disclosure Program Ending: Impact on U.S. Taxpayers,"
with Zhanna A. Ziering, Benjamin Z. Eisenstat, Dianne C. Mehany, and Mark E. Matthews, Caplin & Drysdale Client Alert, March 14, 2018
- "Possible Tax Fallout for Student and Professional Athletes from NCAA-Related Investigations,"
with Victor A. Jaramillo and Mark D. Allison, Caplin & Drysdale Client Alert, November 9, 2017
- "Paradise Papers: U.S. Citizens and Residents Required to Report on Offshore Assets,"
with Mark D. Allison, J. Clark Armitage, Peter A. Barnes, and Kirsten Burmester, Caplin & Drysdale Client Alert, November 6, 2017
- "Treasury Issues Regulations Addressing Use of LLCs to Disguise Beneficial Ownership,"
with Kirsten Burmester and J. Clark Armitage, International Law Office, January 20, 2017
- "Treasury Issues Final Regulations to Address Use of U.S. LLCs to Disguise Beneficial Ownership,"
with Kirsten Burmester and J. Clark Armitage, Caplin & Drysdale Client Alert, December 19, 2016
- "Voluntary Disclosure Window Closing for Bitcoin,"
with Mark E. Matthews, International Law Office, December 16, 2016
- "Voluntary Disclosure Window Closing on Bitcoin Users,"
with Mark E. Matthews, Caplin & Drysdale Client Alert, December 2, 2016
- "U.S. Tax Enforcers React to The Panama Papers,"
IFC Review, September 1, 2016
- "Is the United States Still a Tax Haven? The Government Acts on Tax Compliance and Money Laundering Risks,"
CCH's Journal of Tax Practice & Procedure, July 25, 2016
- "The Panama Papers and the U.S. Response: New Risks for Financial Institutions, Clients and Advisors,"
with Mark E. Matthews and Cono R. Namorato, Caplin & Drysdale Client Alert, May 18, 2016
- "Treasury Announces Regulations to Address Use of U.S. LLCs to Disguise Beneficial Ownership,"
with H. David Rosenbloom, Kirsten Burmester, and J. Clark Armitage, Caplin & Drysdale Client Alert, April 5, 2016
- "IRS/DOJ Summons Seeks to Break Singapore Bank Secrecy on Non-Resident's Account,"
with Mark E. Matthews, Caplin & Drysdale Client Alert, March 7, 2016
- "The Tax Planner's Tightrope: Morality and Politics Now in Play,"
with Sae Jin Yoon, International Law Office, August 14, 2015
- "New Law Changes FBAR Filing Deadline,"
with Zhanna A. Ziering, Charles M. Ruchelman, Mark D. Allison, and Niles A. Elber, Caplin & Drysdale Client Alert, August 10, 2015
- "The Practical Protection of Taxpayers' Fundamental Rights,"
with Dianne C. Mehany and Christopher S. Rizek, International Fiscal Association 2015 Basel Congress, August 1, 2015
- "The Tax Planner's Tightrope: Morality and Politics Now in Play,"
with Sae Jin Yoon, IFC Economic Report, May 5, 2015
- "Switzerland Narrows Advance Notice to Account Holders of Treaty Requests: Americans with Unreported Accounts Impacted,"
with Mark D. Allison and Mark E. Matthews, Caplin & Drysdale Client Alert, December 16, 2014
- "U.S. Offshore Account Enforcement Issues,"
with Zhanna A. Ziering, CCH's Journal of Tax Practice & Procedure, September 30, 2014
- "IRS Modifies Offshore Voluntary Disclosure Program and Streamlined Filing Compliance Procedures,"
with Zhanna A. Ziering, Caplin & Drysdale Client Alert, June 23, 2014
- "Strategies for Current Filings of Noncompliant Taxpayers as FBAR Deadline Approaches,"
Practical Tax Strategies, May 23, 2014
- "Here Comes FATCA…What To Expect In 2014,"
IFC Review Monthly e-Journal, April 1, 2014
- "Here Comes FATCA…What to Expect in 2014,"
IFC Review, January 4, 2014
- "DOJ Deal with Swiss Banks Impacts U.S. Taxpayers and Financial Firms Around the World,"
with Cono R. Namorato, Mark D. Allison, and Mark E. Matthews, Caplin & Drysdale Client Alert, October 31, 2013
- "The Justice Department and Swiss Banks: Understanding the Special Disclosure Program,"
with Mark E. Matthews, Bloomberg BNA, September 24, 2013
- "Here Are the Implications of Singapore's Move to FATCA Compliance,"
Singapore Business Review, July 29, 2013
- "The Crucial Implications of FATCA for U.S. Citizens in Hong Kong,"
Hong Kong Business, July 25, 2013
- "FATCA: A New Era of Financial Transparency,"
AICPA's Journal of Accountancy, January 1, 2013
- "Offshore Tax Evasion: US Initiatives,"
Practical Law Company, April 26, 2012
- "Federal Judge Grants IRS "John Doe" Summons Seeking California Gift Tax Records,"
with Beth Shapiro Kaufman, Caplin & Drysdale Client Alert, December 22, 2011
- "Offshore Tax Enforcement, Voluntary Disclosure, And Undeclared Foreign Accounts,"
ALI-ABA Estate Planning Course Materials Journal, December 1, 2011
- "OVDI Is Over — What's Next for Voluntary Disclosures?,"
with Mark E. Matthews, Tax Notes, Special Report, October 17, 2011
- "Unreported Gifts of Real Property: Time for a Voluntary Disclosure?,"
with Beth Shapiro Kaufman, Tax Notes, August 1, 2011
- "Recent Developments Relating to FBARs and Offshore Voluntary Disclosure Program,"
Caplin & Drysdale Client Alert, June 6, 2011
- "FATCA & Foreign Bank Accounts: Has the U.S. Overreacted?,"
with H. David Rosenbloom, Tax Analysts, May 31, 2011
- "Final Rules & New FBAR Form Issued,"
International Tax Review, May 1, 2011
- "IRS Seeks Names of U.S. Account Holders at HSBC (India),"
with H. David Rosenbloom, Taxmann-The Tax & Corporate laws of India-International Tax, April 18, 2011
- "Indictment of Offshore Account Holder Portends a New Round of Aggressive Enforcement,"
with H. David Rosenbloom, International Taxation, February 1, 2011
- "IRS's Voluntary Disclosure Program for Offshore Accounts: A Critical Assessment After One Year,"
BNA Insights, September 21, 2010
- "More Foreign Financial Account Reporting,"
with James E. Salles and Richard W. Skillman, Caplin & Drysdale Client Alert, March 26, 2010
- "Looking for FBARs in All the Wrong Places? Limited Relief in New Interim Guidance,"
with Patricia Gimbel Lewis, Caplin & Drysdale Client Alert, March 15, 2010
- "Undeclared Foreign Accounts—Voluntary Disclosures and FBARs After the IRS Settlement Initiative,"
Journal of Tax Practice and Procedure, December 1, 2009
- "Voluntary Disclosure Key to Addressing Offshore Tax Cheats, Practitioners Say,"
Tax Analysts, December 8, 2008
- "IRS Issues Revised Foreign Account Reporting Form,"
Tax Analysts, October 1, 2008
- "The IRS’s New Whistleblower Program – Another Enforcement Alert for International Business,"
July 24, 2008
- "Voluntary Disclosure Becomes A Necessity,"
International Tax Review, May 1, 2008
- "Tax Crimes: Has the Bright Line Moved?,"
Law Journal Newsletters, February 1, 2008
- "Developments Aplenty in the KPMG Tax Case: Partial Dismissal, and Court-Ordered Transparency In Entity/Government Negotiations,"
September 30, 2007
- "D.C. Circuit Extends Supreme Court's Interpretation of 'Derivative Use' Under 'Act of Production' Immunity,"
Andrews Litigation Reporter: White Collar Crime, September 1, 2006
- "Deferred Prosecution Agreements: Implications for Corporate Tax Departments,"
The Tax Executive, February 1, 2006
- "Enhanced IRS Enforcement and the Voluntary Disclosure Policy,"
International Law Office, August 26, 2005
- "The IRS Office of Professional Responsibility,"
Business Crime Bulletin, December 1, 2004
- "Criminal Tax Investigations and Current Year Returns: New Thoughts on a Perennial Issue,"
White Collar Crime Reporter (v. 19, Issue 3), December 1, 2004
- "Foreign Bank Accounts - Last Chance for Taxpayers?,"
Caplin & Drysdale, July 1, 2004
- "Corporate Tax Departments and the New Focus on Corporate Criminality,"
The Tax Executive, December 1, 2003
- "If I Had a Hammer,"
Legal Times, June 9, 2003
- "Advising a Client with Secret Offshore Accounts - Current Filing and Reporting Problems,"
Journal of Taxation, September 1, 1999
- "Strategies for Filing a Tax Return While Under a Criminal Tax Investigation,"
Journal of Asset Protection, September 1, 1996
Click here for a full list of publications.