In recent months the Internal Revenue Service (IRS) has started issuing “John Doe” summonses to overseas trust companies and their related entities and vendors to identify clients and obtain their contact information for the purpose of investigating the clients for evading federal taxes using offshore tax havens.
This new approach has significant implications for taxpayers with overseas accounts and assets.
In a new article for Bloomberg Tax, I provide an overview of the IRS’ “John Doe” tactics, summarize what it means for taxpayers with foreign assets and accounts, and discuss how the strategy may be affected by the Department of Government Efficiency’s (DOGE) cost-cutting efforts and the Trump administration’s general approach to enforcement.