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International Tax Eggshell Audits and Recent IRS Enforcement: Assessing Audit Risk for U.S. Residents and Nonresidents

Note: CLE credit is not offered on this program

A live 110-minute CPE webinar with interactive Q&A

This program is included with the Strafford CPE Pass. Click for more information.
This program is included with the Strafford CPE+ Pass. Click for more information.
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Thursday, July 11, 2024

1:00pm-2:50pm EDT, 10:00am-11:50am PDT

or call 1-800-926-7926

This webinar will update international tax advisers on the IRS' current campaign targeting foreign taxpayers and foreign income. Our astute panelist will discuss the IRS' current enforcement actions, outline managing an IRS examination, and highlight offshore voluntary compliance options.


Danny Werfel and the IRS have promised to restore fairness to the tax system and recently reminded taxpayers "of their U.S. tax obligations … to incentivize taxpayer self-correction." Of particular concern is the IRS' focus on foreign taxpayers and U.S. taxpayers with foreign income. The IRS has included more scrutiny on FBAR violations as a Priority Area for Targeted Compliance Work in 2024.

In addition to hiring 3,700 employees to bolster its compliance initiative and the IRS' historical use of Discriminate Function (DIF) Scores, the Service now employs data analytics to hone in on tax evasion and reporting anomalies. Audits of nonresidents and taxpayers with foreign income are particularly risky. So-called eggshell audits can expose these taxpayers to higher risk, higher penalty violations, and criminal sanctions. International tax advisers and multinational taxpayers need to be aware of the current state of IRS examinations and prepare for these upcoming audits.

Listen as our international tax expert reveals how to assess audit exposure risks for U.S. residents and nonresidents with foreign ties.



  1. Update on IRS enforcement
  2. IRS examination approach
  3. Common examples of eggshell audits
  4. Assessing risk for income tax returns of residents
  5. Assessing risk for income tax returns of nonresidents
  6. IR 2023-166: high income, high net worth, non-filer initiatives
  7. Other examination areas
  8. Offshore voluntary disclosure
  9. What's next?


The panelist will cover these and other critical issues:

  • The current state of IRS examinations of international taxpayers
  • Targeted examination areas for multinational taxpayers
  • Assessing audit risk for income tax returns for residents and nonresidents
  • Examples of common issues that generate eggshell audits
  • How the IRS uses the DIF score and data analytics in the audit selection process


Santa, Mishkin
Mishkin Santa, JD, LLM, TEP

Principal, Director of International Tax
The Wolf Group

Mr. Santa focuses his practice on repatriation tax, as well as individual income tax compliance, estate, gift &...  |  Read More

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