NYTimes Quotes Scott Michel: Bank Records Sought in Offshore Tax Inquiry

The New York Times spoke with Scott D. Michel concerning the U.S. government's plan to issue broad requests, known as John Doe summonses, on five Wall Street banks.  The summonses seek data on American clients suspected of hiding assets at the Bank of Butterfield, with offices, in the Caribbean, Guernsey, Switzerland and elsewhere.  This comes after a similar order was issued to Bank of New York Mellon and Citigroup regarding clients with accounts at Zuercher Kantonalbank (ZKB), a major regional bank in Zurich. 

"Nearly every Swiss bank – indeed nearly every bank in the world – has a U.S. correspondent account at a major U.S. bank for processing US dollar transactions," said Scott D. Michel, a tax lawyer at Caplin & Drysdale in Washington. "The accounts provide a road map of leads and information pointing to possible U.S. account holders."  Mr. Michel  added that "we can surely expect many more of these John Doe summonses to hit the New York banking community as the I.R.S. continues to chase the unreported foreign accounts as well as the Swiss banks now under investigation."  For the full story, please visit The New York Times' website.