Enforcing Non-U.S. Tax Authority Requests for Taxpayer Information

In their article for the International Law Office, Charles M. Ruchelman and Arielle M. Borsos discuss governmental tax authorities developing the legal means to obtain information outside of their jurisdictions through bilateral tax treaties or information exchange agreements. The article provides an overview of the information exchange articles under the U.S. Model Income Tax Convention of 2006 ("U.S. model treaty"), as well as the enforcement procedures in the U.S. courts; reviews U.S. case law concerning the enforcement of summonses issued on behalf of treaty partners; and provides practical considerations for non-U.S. taxpayers that find that the IRS has issued a summons on behalf of a non-U.S. tax authority. For the complete article, please click on the link above.