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07.12.12 | Articles

New Offshore Voluntary Disclosure Program: a Carrot Without a Stick?

New York Law Journal

The Internal Revenue Service recently touted the success of its 2009 Offshore Voluntary Disclosure Program and 2011 Offshore Voluntary Disclosure Initiative and provided long-awaited guidance regarding its 2012 Offshore Voluntary Disclosure Program. This article discusses both significant aspects of the new guidance and an IRS initiative to bring taxpayers living overseas into compliance with their U.S. tax obligations.

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