The article discusses the IRS's response to the PFIC problem in the context of the UBS voluntary disclosure initiative. It covers the background of the UBS case, the IRS's voluntary disclosure program, and the tax issues related to passive foreign investment companies (PFICs). The article also highlights the challenges faced by taxpayers and the IRS due to the high volume of cases and lack of information, and explains the IRS's alternative resolution method for dealing with PFIC income.
documents/EFTA01114626.pdf
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