Scott Michel Moderates "Representing the Global Citizen" Panel at National Institute Tax Controversy Conference

Over the past nine years a consensus has formed among most developed countries that tax enforcement along with cooperation and greater transparency as to tax matters are worthy objectives. Automatic information exchange and enhanced communication among tax enforcement authorities have created new challenges for the practitioner advising clients who wish to engage in transactions involving non-taxed funds. Moreover, what might be legal in one country may not be in another. At the same time, many more high net worth taxpayers have footprints in more than one nation, and navigating the varying rules on tax compliance is becoming increasingly complex. Practitioners themselves are under increasing scrutiny in the U.S., the U.K., and elsewhere. This panel will address issues relating to how the U.S. fits into this new environment, including topics such as whether the U.S. itself is a tax haven, whether and how international tax planning can become criminal, how practitioners can address increasing global gatekeeper obligations, and what we can expect next as far as international cooperation.