Scott Michel Interviewed by Geneva's "Le Temps" Regarding Wegelin Guilty Plea

Wegelin, Switzerland's oldest private bank, will close after pleading guilty to helping U.S. citizens evade paying taxes on $1.2 billion held in offshore accounts.  In an interview with Geneva's Le Temps concerning the guilty plea's implications for other Swiss banks, Caplin & Drysdale's Scott D. Michel stated, "The message that DOJ attempted to send with the Wegelin case was threefold.  First, the Department will be aggressive in going after banks in Switzerland (and elsewhere) whose employees actively assist Americans in hiding money.  Second, the US will be particularly aggressive when those banks are thought to have helped Americans move money from banks that might be more vulnerable to US legal process (because they have a US presence) and to have discouraged Americans from entering the voluntary disclosure process.  Third, the US is not limited in these pursuits by any issues of territorial boundaries – a bank with no footprint in the US can be prosecuted just as a bank with a presence here." 

Scott D. Michel is internationally recognized as a leading authority on matters arising from the U.S. government's recent crackdown on undeclared foreign accounts, including criminal tax investigations, sensitive civil audits and voluntary disclosures.  Mr. Michel routinely advises U.S. citizens living abroad and foreign entities doing business in the U.S. about coming into compliance with U.S. tax requirements.  He is currently representing numerous clients worldwide in audits and investigations arising from IRS and Justice Department investigations involving UBS, HSBC and other banks, as well as voluntary disclosures throughout the U.S. involving dozens of foreign financial institutions throughout the world.