A Logical Program Made Unnecessarily Complicated: The IRS’ Approach to International Information Returns

The Difference Between Assessable Penalties and Deficiency Procedures

Applicable Forms and Code Sections

Form 926

Form 5471

Form 8938

The Reasonable Cause Defense

Potentially Applicable Penalties and Additional Amounts Owed

Deficiency Procedures

Collection Due Process Proceedings Challenges in the Current System

Collateral Estoppel Complications

Considerations Regarding Statute of Limitations

Is Filing the Correct Form Necessary?

What Is the True Statute of Limitations?

Navigating the Challenges of International Information Returns

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