Rothschild Comments on the IRS Third Offshore Voluntary Disclosure Program

July 2014

By: Gideon Rothschild

Steve Leimberg Asset Protection Newsletter

Gideon Rothschild provided subscribers to Steve Leimberg's Asset Protection Planning Email newsletter (#253, July 21, 2014) with commentary on changes the IRS recently made to both its Streamlined Procedures and the 2012 Offshore Voluntary Disclosure Program. The latest program is the third iteration of the program commenced in 2009. 

Gideon states that the IRS has made a good faith effort to respond to the practitioner community's comments and criticisms of the OVDI process, particularly the lack of discretion given to examining agents to modify the penalty unless a taxpayer took the risk of opting out of the OVDI. The article provides background about the OVDI, explains new streamlined procedures, and discusses how the modifications may benefit both non-resident taxpayers and US resident taxpayers.


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