In Ryckman v. Commissioner, the U.S. Tax Court tackled an issue of first impression: whether it has jurisdiction over a case challenging the denial by the Internal Revenue Service (“IRS”) of a collection due process (“CDP”)...more
The answer to the question “Can the IRS Collect Assets Abroad”” is yes, based on the Office of Chief Counsel Internal Revenue Service memorandum dated February 24, 2022. The memorandum discusses the IRS Collection Procedures...more
The Internal Revenue Service (“IRS”) faces many challenges when attempting to collect unpaid taxes from taxpayers with foreign assets who reside abroad (“international delinquent taxpayer” or “IDT”). Common obstacles include...more