Kevin M. Johnson

Kevin M. Johnson

Pepper Hamilton LLP

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Latest Publications


As Foreign Banks May Disclose U.S. Depositors, Foreign Account Holders Should Consider IRS OVDI Program

In December, Bank Leumi le-Israel BM issued a letter notifying its U.S. account holders about the IRS Offshore Voluntary Disclosure Initiative (the OVDI). The IRS OVDI is a type of amnesty program under which U.S. citizens...more

3/29/2013 - Bank Leumi FBAR Foreign Banks IRS OVDP Tax Evasion UBS

The Demise of the IRS Tiered Issue Program

In news greatly welcomed by the tax community, IRS Large Business and International (LB&I) Commissioner Heather C. Maloy announced in a directive issued in late August that the IRS is ending its Tiered Issue Program....more

12/3/2012 - IRS

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