1. In recent years, as our economy becomes more global, more and more U.S. taxpayers are participating in offshore activities for both legitimate and illegitimate purposes.
2. Taxpayers who participate in offshore activities for illegitimate purposes seek to shelter financial resources in foreign countries. Offshore accounts can be located in any country in the world. Useful records can be obtained from foreign countries regarding theses taxpayers.
3. International cases require methods not normally used in the domestic arena. Some of these methods are:
   • Exchange of Information (EOI)
   • Consent Directives
   • Letters of Request

1. The United States has tax treaties and tax information exchange agreements (TIEAs) with many countries that provide for the exchange of information on tax matters.
   1. See IRM 5.1.8.7.7, Incoming Mutual Collection Assistance Requests regarding mutual collection assistance requests with the five treaty countries of Canada, Denmark, France, Netherlands and Sweden.
2. The information requested may contain items that are reported or omitted on a taxpayer’s return or regarding the whereabouts of the taxpayer when the taxpayer no longer resides at the last known international address of record and in a delinquent return investigation to determine income and credits of the taxpayer.

   Access a list of countries that have an income tax treaty and/or a TIEA with the United States at: http://www.irs.gov/pub/irs-apa/treaty.pdf

3. All Exchange of Information requests with a foreign country are handled by the IRS Tax Attaché, Revenue Service Representative (RSR) or Exchange of Information (EOI) group, as applicable, with the responsibility for handling request to the country where the information is located.
   1. See IRM 4.60.1 , Exchange of Information for more information on Exchange of Information between the United States and foreign countries.

   Tax Attachés and Deputy Tax Attachés serve in IRS overseas posts of duty and Revenue Service Representatives (RSRs) and Assistant Revenue Service Representatives (ARSRs) serve in IRS domestic posts of duty. Tax Attaches and RSRs service all functions of the IRS in tax administration matters within their respective post jurisdictions.

   
   

   The Exchange of Information Program administers the Exchange of Information provisions of U.S. tax treaties and tax information exchange agreements (TIEAs). EOI helps IRS field personnel obtain information from foreign countries, works with IRS field personnel to provide information to certain foreign countries, and coordinates the Mutual Collection Assistance provisions of certain treaties.

4. All Exchange of Information requests with a U.S. Territory or State are handled by the Office of Governmental Liaison.

1. Exhaust all domestic sources for information before requesting information from a foreign country.

   In general, if the information can be obtained domestically, then a tax treaty or TIEA request is normally not appropriate.

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