Scott Michel to Speak on Offshore Tax Enforcement

08.19.2011
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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