Scott Michel to Speak on Offshore Tax Enforcement
08.19.2011
Program: Developments in Offshore Tax Compliance (Practitioner View)
Event Sponsor: American Law Institute (ALI) CLE, American Bar Association, 14th Annual Advanced Course of Study for Counselors to Foreign and U.S. Clients
Targeted and pattern document requests and examinations; changes to taxpayer "voluntary disclosure" policy and procedure; statutes of limitation in the international tax area; implications of HIREFATCA reporting provisions, and recent developments with foreign financial account reporting on Form TDF 90-22.1 ("FBAR"); IRS enforcement policies and their application, including penalty exposure.
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