Legal Bisnow Profiles Tom Zehnle and Miller & Chevalier's Criminal Tax Practice

"Zehn and the Art of Tax"
Legal Bisnow
02.24.11This article announces the arrival of former DOJ criminal enforcement section chief Tom Zehnle to Miller & Chevalier, and he and George Clarke discuss the firm’s criminal tax practice. The IRS recently announced its second voluntary offshore banking disclosure initiative; the first disclosure period in 2009 generated 15,000 filings. Clarke says over 3,000 IRS voluntary disclosure filings weren’t finished in 2009 and held over to this six-month period, during which filings will depend on how many "people think they’re in trouble." Clarke says offshore foreign accounts and advisors are hot—they tend to get targeted because regulators can take out more than one bird with one stone and want to make an example of them. Zehnle says he brought over a few dozen offshore-account clients, most of whom filed for voluntary disclosure in 2009, and he’s talked to two more about entering this year, as has Clarke.
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