Lackluster Tools For International Collection

I have written and mentioned it before that only 5 treaties provide for assistance in collecting tax judgments against U.S. citizens living abroad..... Canada, France, Holland, Denmark and Sweden.
I’m referring to the ability of the US to collect tax claims against its own citizens who happen to be living in one of these 5 countries. Because these treaties are bilateral, the reverse is also true: partner countries may collect tax claims against their own citizens who happen to be living in the United States. Which means the US has no collection treaties with 190 countries !
The IRS filing a notice of federal tax lien with the foreign taxing authority as is typical in a domestic collections case, or using foreign courts to collect U.S. taxes would not work. These collection devices are useless when it comes to the cross-border collection of taxes.
 One technique that has been getting a lot of attention lately – not to mention gathering up steam – is the “Customs Hold" in connection with TECS data sharing. The procedure for detaining such taxpayers is so simple that it could happen to virtually anyone. First, the revenue officer prepares Form 6668, TECS Entry Request, to have a Customs Hold placed on a delinquent taxpayer. The completed form is sent to the group manager for approval, which consists of nothing more than a signature. After signing it, the group manager emails it to the TECS Coordinator. The TECS Coordinator adds the taxpayer’s name into TECS. Finally, DHS notifies the IRS whenever the taxpayer attempts to reenter the United States. Taxpayers are (theoretically) informed with a Letter 4106, Letter Advising Taxpayer of Department of Homeland Security Notification, that an international revenue officer has notified the DHS “that the taxpayer has outstanding tax liabilities.”

This procedure allows  for brief detainment of the person by a Customs and Border Protection Officer for the purpose of gathering his or her “contact information” (i.e., “where he will be staying while in the United States”). Nothing more. Nothing less. In other words, while it is supposed to be a tool for collecting taxes from delinquent taxpayers, it offers no ironclad guarantee that the person being detained will actually pay the tax. Holding individuals as they seek to return to the United States only works as a collection device if the experience itself was so emotionally traumatic as to convince them to pay. At a primitive level, it only works if it instills the fear of God in the taxpayer.
While it might potentially cause the person some alarm, it’s hard to imagine that it will have the desired effect of inspiring taxpayers to take out their checkbooks and write out a check to Uncle Sam. And before we can even get to that point, do not forget that the person has to attempt to reenter the United States. Suffice to say, it would be a cold day in hell before someone who receives Letter 4106 steps foot back in the United States again.
 According to recent statistics, there are approximately 1,700 taxpayers on the TECS with approximately $ 1.6 billion in delinquent tax assessments. This includes assessments of approximately $ 1.1 billion exclusively owed by international taxpayers.