Assessing tax liabilities is one thing, collecting them abroad is another : new case shows international reach of the IRS

Resource Information

The work Assessing tax liabilities is one thing, collecting them abroad is another : new case shows international reach of the IRS represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Continuing Resources.

Label

Assessing tax liabilities is one thing, collecting them abroad is another : new case shows international reach of the IRS

Creator

• Sheppard, H.E

Subject

• collection of tax
• case law
• voluntary disclosure
• tax liability
• exchange of information
• penalties

Language

eng

Summary

People have many misconceptions when it comes to international tax. A recent case, Dewees, highlights several common fallacies, including: (1) if a taxpayer enters into the Offshore Voluntary Disclosure Program (OVDP) in order to resolve past international tax non-compliance on the most favourable terms possible, the IRS will simply forget about such taxpayer if he or she later decides to stop participating in the OVDP; (2) the IRS will be compassionate in determining whether penalties for unfiled Forms 5471, Information Return of U.S. Persons with Respect to Certain Foreign Corporations, should be asserted; and (3) if a taxpayer lives abroad and lacks U.S. assets, then the IRS will not be able to collect any U.S. tax liabilities. This article analyses and debunks these widespread myths, using Dewees as a point of reference

Citation source

In: Journal of taxation. - New York. - Vol. 127 (2017), no. 5 ; p. 205-217

Geographic coverage

North America

Language note

English