Stephen Josey to Join NYU Tax Controversy Forum

Cases raising cross-border issues often raise complex substantiation issues when documents or other information located abroad are needed to examine or sustain a return reporting position. This panel will discuss offshore information gathering techniques available to the IRS including FATCA research, exchange of information requests, consent directives and letters of request. While more broadly available to the IRS than to taxpayers, it can be advantageous for taxpayers to encourage the IRS to pursue these techniques, including in cases where the taxpayer may carry the burden of proof.

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