The U.S. IRS recently published a memorandum containing legal advice in regard to the Collection Procedures for Assets Located Outside the United States. Among other things, the memorandum addresses a question of whether the IRS is prohibited from pursuing multiple collection activities simultaneously, as follows. The memorandum also addresses the use of FATCA data to identify and select collection cases, the use of internal databases to identify collection accounts likely to qualify for collection actions, and other related matters. --- QUESTION 1 Once the IRS has attempted to contact the taxpayer, the taxpayer has neglected or refused to pay, and...