The Resource Extended assessment periods and international tax enforcement : M. Rafizadeh, unreported foreign assets, and use of FATCA weapons

Extended assessment periods and international tax enforcement : M. Rafizadeh, unreported foreign assets, and use of FATCA weapons

Label
Extended assessment periods and international tax enforcement : M. Rafizadeh, unreported foreign assets, and use of FATCA weapons
Title
Extended assessment periods and international tax enforcement : M. Rafizadeh, unreported foreign assets, and use of FATCA weapons
Creator
Subject
Language
eng
Summary
When Congress wants to reduce what it considers offshore tax cheating, it can do many things, including enacting laws forcing U.S. persons to report the existence of foreign assets, severely penalizing information-reporting violations, and giving the IRS more time to find the offenders by extending assessment-periods. For its part, the IRS can devote significant resources to international enforcement and take aggressive positions in applying the laws passed by Congress. A good example of this is a recent Tax Court case, M. Rafizadeh. It centers on several provisions created by the Foreign Account Tax Compliance Act (FACTA) and the IRS's quest to seek taxes and penalties from earlier years by using an expansive interpretation of assessment-periods. This article analyses the pertinent aspects of FATCA, special issues related to Form 8938 (Statement of Specified Foreign Financial Assets), and IRS pronouncements and court precedent demonstrating how the IRS employs FATCA tools to attack multiple returns over multiple years in situations involving unfiled Forms 8938 and other international information returns
Citation source
In: International tax journal. - Riverwoods. - Vol. 44 (2018), no. 5 (September-October) ; p. 29-39
http://library.link/vocab/creatorName
Sheppard, H.E
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • FATCA
  • case law
  • assessment
  • information return
  • enforcement
  • penalties
Label
Extended assessment periods and international tax enforcement : M. Rafizadeh, unreported foreign assets, and use of FATCA weapons
Instantiates
Publication
Label
Extended assessment periods and international tax enforcement : M. Rafizadeh, unreported foreign assets, and use of FATCA weapons
Publication

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