Fairness in Foreign Filing Act amends the Internal Revenue Code to treat tax penalties as assessable in the same manner as taxes and establishes.

The Fairness in Foreign Filing Act amends the Internal Revenue Code to treat tax penalties as assessable in the same manner as taxes. It requires the Secretary of the Treasury to provide taxpayers with written notice before assessing certain penalties. The notice must include details about the proposed penalty, the taxable years involved, the basis for the penalty, and the taxpayer's right to request a review. The taxpayer has 60 days (120 days for those outside the U.S.) to request a review by the Internal Revenue Service Independent Office of Appeals.

Fairness in Foreign Filing Act amends the Internal Revenue Code to treat tax penalties as assessable in the same manner as taxes and establishes.

The Fairness in Foreign Filing Act amends the Internal Revenue Code to treat tax penalties as assessable in the same manner as taxes. It requires the Secretary of the Treasury to provide taxpayers with written notice before assessing certain penalties. The notice must include details about the proposed penalty, the taxable years involved, the basis for the penalty, and the taxpayer's right to request a review. The taxpayer has 60 days (120 days for those outside the U.S.) to request a review by the Internal Revenue Service Independent Office of Appeals.