Extensions in the statute of limitations are said by some to be needed due to the complexity of the
international cases and difficulty of obtaining information. Extension has been proposed by
numerous commentators, is supported by the IRS officials and is included in the proposed Stop
Tax Haven Abuse Act, proposals discussed by the Senate Finance Committee, and proposals made by President Obama. These legislative proposals would extend the statute of limitations
from 3 years to 6 years, but Blum also suggests the possibility of 10 years. The HIRE Act (P.L.
111-147) extends the statute of limitations to six years.