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The new offshore disclosure framework offers a more flexible penalty structure than the previous Offshore Voluntary Disclosure Program (OVDP). This may benefit some taxpayers, but it could also result in large penalty assessments for others. The following penalties...
The new offshore disclosure framework has once again provided a disclosure option for taxpayers who wish to protect themselves from criminal liability for their undisclosed offshore accounts. However, the Streamlined Filing Compliance Procedures still offer a good...
The IRS closed the 2014 Offshore Voluntary Disclosure Program in September of 2018, leaving taxpayers with unreported foreign accounts with fewer disclosure options. In November of 2018, the IRS issued a new framework for resolving offshore voluntary disclosure...