The IRS Stacks International Penalties in Foreign Trust Disputes: Two Recent Cases Reveal the IRS’s Playbook

 



Kicking people when they are down is one thing, but doing it repeatedly is another. Several recent cases demonstrate that the IRS is doing exactly that. This process, often referred to as “stacking” penalties, means imposing multiple sanctions against the same taxpayer, for the same year, in connection with the same problem. The article explains common U.S. international tax duties, the current “compliance campaign” focused on foreign trusts, and two recent cases showing how the IRS uses penalty stacking as a serious enforcement tool.

Read the full article here.

About Hale E. Sheppard
HALE E. SHEPPARD, Esq. (B.S., M.A., J.D., LL.M., LL.M.T.) is a Shareholder in the Tax Controversy Section of Chamberlain Hrdlicka and Chair of the International Tax Group.

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