Earlier today, IRS Commissioner Douglas Shulman addressed the 24th Annual Institute on Current Issues in International Taxation which is sponsored by the George Washington University School of Law and the IRS. As always, those of us who work in the "tax world" listen carefully to the comments made by the Commissioner in order to understand the direction in which the IRS is moving, areas of focus and concern. Almost the very first words by the Commissioner were "tax evasion" and of the two areas discussed by the Commissioner, offshore tax evasion was first. The second area to which the Commissioner addressed his comments was multinational companies.

The IRS views the two voluntary disclosure programs for reporting offshore bank accounts, the second of which closed recently, as having been very successful with over $4 billion dollars collected so far. In these programs, taxpayers came forward to report previously unreported offshore bank accounts as well as income associated with them. Although officially there is no new program being implemented by the IRS to come forward to report previously unreported offshore bank accounts according to the Commissioner, the area of offshore tax evasion continues to be a significant focus by the IRS.

The Commissioner made a strong distinction between offshore tax evasion and multinational companies conducting business in various parts of the world. In this area, he emphasized that the IRS is making a strong effort to understand the business operations to enable them to better focus their resources and attention - pursuit of significant issues rather than items that might utilize resources with little or no benefit to the Treasury.