By Robin Greenhouse and Kevin Spencer ( March 14, 2018, 6:09 PM EDT) -- The United States and its treaty partners frequently exchange information to aid in the tax investigations of taxpayers residing or doing business in their respective countries. If the requested information is in the taxing authority's possession, the taxpayer may be unaware when these exchanges are occurring. When the Internal Revenue Service, however, receives a treaty request for information that is not already in its possession, the IRS may use its summons authority to gather the requested information.[1] If an administrative summons is issued, the taxpayer is not without procedural rights. The IRS must provide notice of the summons to the person for which information is sought, who may bring a proceeding to quash the summons in U.S. federal district court.[2]...