Based on recent events in Liechtenstein, and the IRS aggressive increase in tax audits, I have extensively researched international tax compliance for U.S. taxpayers with foreign assets. Please see memos:

1) IRS Tax Audit Strategy

2) Foreign Bank Accounts (“FBAR” – TD F 90-22.1)

3) Foreign Trust (U.S. Person): Reportable Event

4) Foreign Trust (U.S. Tax Reporting)

5) Foreign Gifts (U.S. Person)

6) Foreign Disregarded Entity (U.S. Owner) Form 8858

7) Foreign Corporation (Form 5471) - Foreign Partnership (Form 8865)

8) Definition of U. S. Person