New 2012 Offshore Voluntary Disclosure Program; Taxpayer Advocate Criticizes IRS "Bait & Switch"; Current Offshore Enforcement Initiatives

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A taxpayer contemplating a voluntary disclosure also may want to consider the differences in the financial consequences of participating in the new program, opting out of the new program or making a traditional voluntary disclosure.

2012 Offshore Voluntary Disclosure Program Announced by IRS: Details and Issues

On January 9, 2012, the Internal Revenue Service (IRS) announced that it had reopened the Offshore Voluntary Disclosure Program (OVDP) following the closure of the 2011 and 2009 programs and the collection of more than $4.4 billion USD from those programs. The third offshore program comes as the IRS continues working on a wide range of international tax issues and follows ongoing efforts with the U.S. Justice Department to pursue criminal prosecution of international tax evasion.

The new program will be open for an indefinite period of time, and its terms could change over time.

The program is similar to the previous programs, but with a few key differences. The previous programs had a deadline for applying; the new program has no application deadline.

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