Beyond Information Document Requests: Tools The IRS Uses To Obtain Information From Foreign Countries

Many U.S. taxpayers express bravado with respect to their records in foreign countries, commonly exclaiming "the IRS can't get that—it's overseas" in strategy conferences with their tax attorneys. However, these taxpayers are misguided. In addition to the traditional method of obtaining information via Information Document Requests, the International Examiners of the IRS have numerous tools at their disposal to acquire information from abroad.

Before reviewing these tools, an initial problem confronting U.S. taxpayers is that most of their foreign offices do not have records that are in a usable format, as records are often prepared in foreign languages. Must a U.S. taxpayer spend a large amount of time and money translating the documents into English for the IRS?