Pre-Clearance

News & Analysis as of

OVDI Pre-Clearance Letters And Their Revocability

The first step a taxpayer with undisclosed or unreported offshore accounts or assets undertakes in seeking to enter the Offshore Voluntary Disclosure Initiative (OVDI) is to apply for pre-clearance from the IRS Criminal...more

Bank Leumi Snafu Jeopardizes DOJ-IRS Offshore Enforcement Initiatives

Three times over the past four years, the IRS has given taxpayers with undisclosed offshore accounts the opportunity to come clean and avoid prosecution. While the most recent offer – the 2012 Offshore Voluntary Disclosure...more

DOJ Revokes Some Pre-Clearances for Bank Leumi Depositors

A recent press release should send a shudder to some voluntary disclosure participants. It should frighten some tax preparers and their clients....more

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