The U.S. Treasury Inspector General for Tax Administration (TIGTA) has released a partially redacted report dated 26 August 2024 on the challenges faced by the IRS to address avoidance strategies of large multinational corporations. The primary concern covered in the report is in relation to the IRS's efforts to raise the Economic Substance Doctrine argument relating to a specific foreign trust structure that large multinational corporations can use to reduce or avoid U.S. taxation. Other specific concerns were raised while TIGTA performed its review, including: Concerns regarding the ability of large multinational corporate taxpayers to directly contact IRS executives; Concerns...