Handing Audits of Delinquent International Information Returns

This article examines strategies for handling an IRS investigation of international returns and recommends ways to improve audits, foster taxpayer compliance, and uphold taxpayers’ rights. The IRS has been pushing for compliance in the offshore area for some time. It began over 10 years ago with the launch of the offshore voluntary disclosure program in 2009.

The IRS offered modified versions of the OVDP in 2011, 2012, and 2014 as more taxpayers came forward to handle their offshore issues from countries around the world. The programs were designed for taxpayers who have exposure to potential criminal liability or substantial civil penalties due to a willful failure to report foreign financial assets and pay all taxes due on those assets.

2020-05-25 - Tax Notes_Handing Audits International.pdf

Download PDF • 862KB