Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 26 AUGUST 2021

Offshore Lenders Targeted By IRS Audit Campaign

Holland & Knight
Explore more from Holland & Knight

Since 2017, the Internal Revenue Service (IRS) Large Business and International Division (LB&I) has shifted its audit efforts to issue-based examinations...

United StatesTax
Alan Winston Granwell
Alan Winston Granwell
Abbey Benjamin Garber
Abbey Benjamin Garber
William Sharp
William Sharp
Author LinkedIn connections

Highlights

  • Offshore lenders have become the latest target of an Internal Revenue Service (IRS) audit campaign because of concern that foreign lenders are not properly reporting or paying U.S. tax on certain types of "inbound" lending transactions.
  • The IRS wants to audit more returns in this area because, absent an IRS review of the underlying facts and circumstances, the agency is unable to ascertain whether the return has been properly prepared and filed.
  • This IRS campaign, announced on June 10, 2021, without much fanfare, is reflective of the agency's interest in activities of "inbound" taxpayers, particularly those engaging in offshore lending to U.S.-based borrowers.

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

GENIUS Act Crypto Tax Guide 2025-2026: What US Investors, Businesses, And Taxpayers Need To Know About The New Stablecoin Law, Form 1099-DA, And Digital Asset Regulation

The United States cryptocurrency regulatory landscape has undergone its most dramatic transformation in history. The signing of the GENIUS Act into law on July 18, 2025 — the first comprehensive federal crypto statute ever enacted — marks a before-and-after moment for American digital asset law.
United StatesTax
Rotfleisch & Samulovitch P.C.
Rotfleisch & Samulovitch P.C.
Article

A 5% Wealth Tax? Preparing Clients For California's Billionaire Tax Act

California's proposed Billionaire Tax Act would impose a onetime 5% excise tax on individuals and trusts with assets exceeding $1 billion, creating unprecedented challenges for estate planners. The retroactive application and anti-abuse provisions raise critical questions about the treatment of grantor trusts, non-grantor trusts, and beneficiary interests that deviate significantly from established federal wealth transfer tax principles.
United StatesTax
Withers LLP
Withers LLP
Article

IRS Proposes New Racial Nondiscrimination Regulations For Tax-exempt Private Schools

The US Treasury and IRS have proposed regulations that would eliminate longstanding exceptions allowing tax-exempt private schools to maintain race-conscious admissions and scholarship policies. Following the Supreme Court's decision in Students for Fair Admissions v. Harvard, these rules would apply to all private educational institutions, including K-12 schools not directly affected by that ruling, and could result in loss of tax-exempt status for noncompliance.
United StatesTax
McDermott Will & Schulte
McDermott Will & Schulte