26 USC 982 - Admissibility of documentation maintained in foreign countries

U.S Code last checked for updates: Nov 23, 2024

§ 982.

Admissibility of documentation maintained in foreign countries

(a)

General rule

(b)

Reasonable cause exception

(1)

In general

(2)

Foreign nondisclosure law not reasonable cause

(c)

Formal document request

For purposes of this section—

(1)

Formal document request

The term “formal document request” means any request (made after the normal request procedures have failed to produce the requested documentation) for the production of foreign-based documentation which is mailed by registered or certified mail to the taxpayer at his last known address and which sets forth—

(A)

the time and place for the production of the documentation,

(B)

a statement of the reason the documentation previously produced (if any) is not sufficient,

(C)

a description of the documentation being sought, and

(D)

the consequences to the taxpayer of the failure to produce the documentation described in subparagraph (C).

(2)

Proceeding to quash

(A)

In general

(B)

Jurisdiction

(C)

Suspension of 90-day period

(d)

Definitions and special rules

For purposes of this section—

(1)

Foreign-based documentation

(2)

Documentation

(3)

Authority to extend 90-day period

(e)

Suspension of statute of limitations

(Added Pub. L. 97–248, title III, § 337(a), Sept. 3, 1982, 96 Stat. 629; amended Pub. L. 98–369, div. A, title VII, § 714(k), July 18, 1984, 98 Stat. 963.)

cite as: 26 USC 982