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Time Will Not Make This Problem Disappear: The Open-Ended Statute Of Limitations For Taxpayers With Delinquent Foreign Information Returns

By Megan L. Brackney
American Bar Association Tax Times
Volume 35, No. 2 – February 2016

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.


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