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Tax News
Another Special Offshore Voluntary Disclosure Program in the Cards
December 12, 2010
Administrative Actions
By now everybody has heard of the UBS case and the crackdown on offshore tax evasion.  The case was part of an orchestrated effort by the IRS to put a stop on hiding money offshore.  As part of this effort the IRS introduced the Special Voluntary Disclosure Program which brought in approximately 15,000 disclosures from individuals holding foreign accounts.  Many U.S. investors who have been less than forthcoming regarding their offshore holdings, including accounts in foreign private equity and hedge funds, took advantage of this program.  However, the program closed in 2009.  Since then, there has been speculation whether there will be another program of this nature.  On December 9, 2010, Commissioner Doug Shulman spoke before the 23RD Annual Institute on Current Issues in International Taxation and alluded that another special program is in the cards.  However, there will be differences.  To quote the Commissioner "Taxpayers will not get the same deal as those who came in under the original program. To be fair to those who came in before the deadline, the penalty – and thus the financial cost to participate – will increase. Let me say too that we expect to make the terms of any new program available to those who have already come in after October 2009 when that program expired." It remains to be seen what the exact scope of this new program will be.  The full speech could be found on the IRS' website at http://www.irs.gov/irs/article/0,,id=232223,00.html
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Tags: IRS voluntary disclosure, Special Offshore Voluntary Disclosure, SVDP, Voluntary Disclosure