Scott D. Michel is a member of Caplin & Drysdale, has been at the firm since 1981, and currently serves as the firm's President. He advises and represents individuals and corporations nationwide in voluntary disclosures; assisting U.S. citizens living abroad and foreign entities doing business in the U.S. about coming into tax compliance; sensitive civil tax examinations where fraud or substantial penalty issues may arise; criminal tax fraud investigations; corporate internal investigations of tax and financial related matters, and tax shelter matters, including criminal and civil penalty examinations of tax shelter promoters and professionals.
Mr. Michel is internationally recognized for his extensive experience in handling matters arising from the U.S. government's recent crackdown on undeclared foreign accounts, including criminal tax investigations, sensitive civil audits and voluntary disclosures. Such matters encompass a broad range of fact patterns, such as inherited accounts, situations that raise issues of complex undisclosed corporate or foundation structures, and unfiled Treasury "FBAR" forms. 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.
Mr. Michel has made frequent appearances throughout the U.S., and in Seoul, Singapore, Hong Kong, Vienna, Zurich and Geneva for presentations on enforcement regarding foreign accounts and the Foreign Account Tax Compliance Act to multiple law firms, bankers, and tax and financial advisors, including presentations before the National University of Singapore, the Tax Academy of Singapore, the Vienna University of Economics and Business, the Korean National Tax Service, Hong Kong University, and the Korean and the Swiss-American Chambers of Commerce. He is the co-chair of the ABA Section of Taxation's Annual Conference on International Tax Enforcement, and has also appeared at other programs held by the American Bar Association, 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.
He has also testified as an expert on offshore account enforcement before the Standing Committee on Finance of the Canada House of Commons. Mr. Michel is an Adjunct Professor of Law at the University of Miami School of Law Graduate Program in Taxation. He is also a Fellow of the American College of Tax Counsel, and currently serves as a Council Director for the ABA Section of Taxation. He previously chaired the Tax Section's Committee on Civil and Criminal Tax Penalties and the Standards of Tax Practice Committee.