Pocedurally Taxing  recently posted regarding Dave Breen's, the acting Director of Villanova’s Low Income Taxpayer Clinic, view regarding the case of Greenfield v US; a recent IRS setback in a summons enforcement case out of the Second Circuit.

Dave's take on this recent case is that taxpayers and some practitioners may believe that the era of IRS investigating offshore tax evasion has run its course.  He thinks this case does just the opposite.

The Court’s decision demonstrates that much of IRS’s data on offshore tax evasion is dated, possibly even too old to be of any value, but he also suspect that IRS has come to the same conclusion. 

Rather than moving on to other areas of non-compliance though, he suspects that the IRS at this moment is developing more tools to secure the next wave of current information on offshore tax evasion.  This does not bode well for taxpayers who so far have avoided IRS’s inquiry into their offshore holdings. To Read More...