Statute of Limitations for Foreign-Related Items

Taxes are generally required to be assessed by the I.R.S. within three years after a taxpayer’s return is filed. Code §6501(a). In the case of a false or fraudulent return filed with the intent to evade tax, or if the taxpayer fails to file a required return, the tax may be assessed at any time. Code §6501(c)(1), (2), and (3). Code §6501(c)(8) provides an exception to the three-year period of limitations due to failures to... Read more →