In Coffey v. Comm'r, 987 F.3d 808 (8th Cir. 2021), the U.S. Court of Appeals for the Eighth Circuit reversed and remanded the U.S. Tax Court's decision in Coffey v. Comm'r, 150 T.C. 60 (2018). The Eighth Circuit held that, for statute of limitation purposes, a federal income tax return had not been filed even if the IRS received and stamped as received certain tax return documents from the U.S. Virgin Islands' Bureau of Internal Revenue. This Holland & Knight alert explores the decision and its potential impact to a new IRS Large Business and International (LB&I) compliance campaign involving Puerto Rico Act 22, known as the "Individual Investors Act," and I.R.C. § 937.