In a recent Law360 article, Kat Gregor comments on a recent Treasury Inspector General for Tax Administration report that highlights the IRS’ stalled enforcement of the Foreign Account Tax Compliance Act (“FATCA”). This stalled enforcement demonstrates that although the agency has cracked down on unreported offshore accounts, there are associated logistical challenges that must considered. Kat notes that the IRS “has a lot of data” and that it would be “difficult for any entity to use such a high volume of data effectively.” She also states that one of the “IRS’ goals should be giving the appearance of an effective, efficient enforcement, so people believe that there will be consequences.”

  • Click here to read the full article, including more insights from Kat.
  • Click here to read another Disputing Tax article focused on potential replacement of the offshore voluntary disclosure program discussed in this posting.