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Pre-Clearance Not An Option As OVDP Deadline Looms

Law360 (August 10, 2018, 11:28 AM EDT) -- On March 13, 2018, the Internal Revenue Service announced that it would end its offshore voluntary disclosure program, or OVDP, on Sept. 28, 2018. When the IRS announced that it was ending the program, it noted that taxpayers “who still wish to come forward have time to do so.” It has been widely assumed that this meant that taxpayers had until September 2018 to take full advantage of the program if they so choose.

That is no longer true. Until recently, taxpayers could confirm their eligibility...
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