Time Will Not make This Problem Disappear: The Open-Ended Statute of Limitations for Taxpayers with Delinquent Foreign Information Returns

By Megan L Brackney
ABA Tax Times - Vol. 35 No. 2
February 2016 Edition

Although section 6501(c)(8) has been in the Code for several years, many tax practitioners remain unaware of this exception to the general three-year statute of limitations for assessment of tax for delinquent foreign information returns. This exception can significantly influence a taxpayer’s decision as to whether, and how, to correct past non-compliance. This article first discusses the exception, and then describes the alternative methods for late filing of foreign information returns.