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Updated Guidance for IRS Voluntary Disclosure Practice
By: Eli S. Noff, Esq., CPA, Partner & Mary Lundstedt, Esq., Associate The objective of the recently expired Offshore Voluntary Disclosure Program (OVDP) enabled willful U.S. taxpayers with undisclosed foreign assets to become compliant with U.S. tax laws, while concurrently avoiding serious statutory civil penalties and practically removing any risk of criminal prosecution. On November