Bryan C. Skarlatos, partner at Kostelanetz LLP, was quoted in an article published in Tax Notes on August 23rd, 2023 titled “The FATCA Haystack Remains Just That.” The article discusses unknowns regarding data collected by the Internal Revenue Service through the Foreign Account Tax Compliance Act. Though the IRS strategic operating plan released on April 6th does not mention FATCA, data collected through the FATCA could have significant implications for taxpayers under investigation, taxpayers undergoing audits, or taxpayers pursuing voluntary disclosures.
The article notes:
“They do use it for purposes of audits and soft letters and denying voluntary disclosures,” Bryan Skarlatos of Kostelanetz LLP said. “When you go into a civil audit or a criminal investigation that could involve unreported foreign assets, you have to take into account the reality that there’s a very good chance the IRS has the info on the foreign account.”
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