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Tax Notes Quotes Scott Michel: Non-Willfulness Not Only Streamlined Filing Claim U.S. DOJ Checking

October 31, 2016, Tax Notes

According to the head of the Tax Division of the U.S. Justice Department, DOJ continues to review submissions by Swiss banks participating in the DOJ’s Swiss Bank Program, and other sources of data, looking for evidence that U.S. taxpayers may have provided false information during an IRS offshore disclosure.

While interviewing Caroline Ciraolo, the Tax Division’s Principal Deputy Attorney General, at a conference sponsored by the Association Section of Taxation, conference co-chair Scott D. Michel of Caplin & Drysdale referenced DOJ’s prior comments about how they were following up on streamlined disclosures, and Ms. Ciraolo confirmed that DOJ was reviewing whether taxpayers may have submitted false “non-willful” certifications and other disclosure-related documents, including expatriation forms, to ascertain whether they may have somehow abused the IRS’s offshore disclosure procedures.  For the full article, please visit Tax Notes’ website (subscription required).

Excerpt taken from the article “Non-Willfulness Not Only Streamlined Filing Claim U.S. DOJ Checking” by Nathan J. Richman for Tax Notes. 

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