From Summonses to International Evidence Gathering Techniques: How the IRS Gathers Evidence in the 21st Century (Video) (Course Id 2676)

• Who is this course for?
  This course is intended for anyone needing Continuing Professional Education (CPE), including CPAs, accountants, and IRS Enrolled Agents.

• What is this course about or what problem does this course solve?
  The course explores how the IRS gathers evidence both domestically and internationally, addressing traditional and modern investigative methods to enhance understanding of U.S. and global tax compliance procedures.

• How can the knowledge from this course be used?
  Participants can use this knowledge to better understand the legal and procedural framework of IRS evidence gathering, enabling them to navigate compliance issues, client advisories, or legal tax matters more effectively.

• Why is this course important to a CPA, Accountant, or IRS Enrolled Agent?
  Understanding the IRS’s investigative tools and international cooperation mechanisms is crucial for professionals advising clients or ensuring organizational compliance with U.S. tax laws.

• When is this course relevant or timely?
  With the course released in 2025 and covering current methods like FATCA and international treaties, it is highly relevant for modern tax practice in an increasingly globalized economy.

• How is a course like this consumed or used?
  This is a video-based self-study course that includes review and final exam questions, and is accessed online with no prerequisites or additional materials needed.

This presentation will teach you how the government gathers information both domestically and internationally in the 21st century. There are tried and true methods that have been around since time and memorial as well as new techniques such as FATCA. We'll begin on the domestic side with IRS summonses, subpoenas, search warrants, and sting operations and then make our way to international evidence gathering. Specifically, we'll discuss mutual legal assistance treaties, tax treaties, information exchange agreements, FATCA, and letters rogatory.

Video - NASBA QAS - NASBA Registry - IRS Enrolled Agents - 2676

Course Learning Objectives

1. How do dual-purpose summonses differ from traditional summonses issued by the IRS, and what implications do these differences have for taxpayer privacy?
2. What challenges might the IRS face when utilizing grand jury subpoenas compared to administrative summonses, particularly in terms of compliance and enforcement?
3. In what ways have international business practices influenced the evolution of the IRS's evidence-gathering techniques, particularly regarding tax fraud?
4. How does the Foreign Account Tax Compliance Act (FATCA) alter the relationship between U.S. taxpayers and foreign financial institutions in terms of information disclosure?
5. What are the potential ethical dilemmas faced by foreign financial institutions when complying with U.S. tax laws, particularly in jurisdictions with strict bank secrecy laws?
6. How effective are Mutual Legal Assistance Treaties (MLATs) in facilitating international cooperation for tax enforcement, and what limitations do they face?
7. In what scenarios might letters rogatory be preferred over other methods of international evidence gathering, and what are the potential drawbacks of this approach?
8. How does the IRS balance the need for efficient evidence gathering with the rights of taxpayers during international investigations?
9. What role does judicial oversight play in the issuance of John Doe summonses, and how does this impact taxpayer rights and protections?
10. How can the IRS improve its strategies for combating international tax evasion while still respecting the privacy and legal rights of individuals?
11. What lessons can be learned from historical cases where IRS summonses were deemed unenforceable, and how might these lessons inform current practices?
12. How does the U.S. government's approach to international tax compliance compare with that of other countries, and what are the implications for global tax policy?

Chapter 1 - From Summonses to International Evidence Gathering Techniques: How the IRS Gathers Evidence in the 21st Century (Video)

Chapter 1 Review Questions