International Information Reporting: Recent Developments and Strategies

Tax attorney Andrea Darling de Cortés will join a STEP Mid Atlantic Hybrid Program titled "International Information Reporting: Recent Developments and Strategies." This session will discuss efforts by the IRS to prioritize international information reporting as an area for enforcement activity.

Topics include:

• the current landscape of IRS information return enforcement activity
• IRS enforcement focuses on high-income taxpayers under Inflation Reduction Act Strategic Operating Plan
• recent case law on information return penalties and implications, including Bittner, Farhy, Fairbank and Wrzesinski
• proposed regulations under IRC 6751 on supervisory approval of penalties 
• compliance options and strategies for addressing penalties