Fourth Time's A Charm: IRS Finally Gets Its OVDP Right
Law360, New York (June 26, 2014, 9:40 AM EDT) -- The IRS has for the last several years been focusing on shutting down tax havens. Since at least 2009, it has been using both a carrot (a "favorable" amnesty program) and a stick (threats of criminal prosecution and crippling civil penalties) to get taxpayers residing in the U.S. and abroad to comply with their obligations to report foreign assets and to pay taxes on income generated from those assets.
Unsurprisingly, the IRS had a jaundiced view about the reasons for noncompliance with reporting obligations. Assuming that most taxpayers with offshore accounts established them to evade income taxes, the IRS tailored its...
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