U.S. Court Rules No Advance Notice Required for Foreign Tax-Related IRS Summonses

            On September 17, 2026, the United States District Court for the Northern District of California in an opinion by Judge Vice Chhabria ordered the enforcement of IRS summonses issued to banks at the request of the South Korean National Tax service, holding that the IRS properly relied on the South Korean government’s representations and that the individual under investigation was not entitled to advance notice since the summonses related to foreign taxes.