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    Hello Dr. Vinícius! As always, great posts, thank you!

    One question: in a worst-case scenario where a non-resident has filed a tax return, he has kept investments with income above the minimum. If there is a cross-check of information and the RFB makes the CPF pending regularization, what are the consequences in this case? Would there be a fine? Would I be obliged to liquidate all the investments and regularize the situation? Could you give us an example of a real case where this has happened and how the process of regularization went?

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Hi, I'm Vinicius Tersi, a specialist in international tax law.

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