February 2018 JD Supra

At a certain point during an income tax examination, if the IRS determines that it needs documents or items located outside the U.S., it may issue a Formal Document Request (FDR) under the Internal Revenue Code Section 982 (IRC 982).  https://www.jdsupra.com/legalnews/if-irs-wants-to-obtain-records-held-in-47333/