International Tax Enforcement Update

The year's update reviews the life-cycle of an international tax controversy including (a) the most common errors on returns required to be filed by US Persons reporting foreign assets and income, (b) the procedures used by the IRS to determine a liability based on foreign income, deductions, and assets, (c) the options available to contest and compromise the international adjustments and penalties before the IRS Office of Appeals, including accelerated appeals, collection due process hearings, and (d) the best practices for litigating international issues in the Tax Court and other federal courts.