The IRS and Department of Justice in the United States continue to pursue US
persons with offshore accounts, and have redoubled their resources in various
countries around the world, including those in Asia.
This briefing will explore the effect of investigations of non-US financial institutions
on the practical alternatives available to US persons living abroad, and will provide
an update regarding the US voluntary disclosure program and associated penalties
and issues.
Mr. Frewing and Mr. Webber are US tax litigation partners with Baker & McKenzie
based in San Francisco and Washington DC respectively. Mr. Frewing's practice
focuses upon representing individuals and corporations in civil and criminal tax
audits and litigation. He was previously an Assistant United States Attorney with
the U.S. Department of Justice. Mr. Webber served for many years as Chairman
of the Baker & McKenzie North American Tax Group. His practice focuses upon
resolution of US Federal income tax controversies with the IRS. Mr. Michaels,
based in Zurich, represents financial institutions and individuals with respect to
US tax matters.
