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By Benjamin Tolub, Esq., Armin Gray, Esq., and Julia Benarroch *
The U.S. tax authorities (IRS) made recently major changes to its amnesty programs. These changes can be broken into two parts: changes to the 2012 Offshore Voluntary Disclosure Program (“O.V.D.P.”), which can be to referred to as the 2012 Modified O.V.D.P. or the 2014 O.V.D.P., and changes to the streamlined procedures (“Streamlined Procedures”). As the requirements for the latter are relaxed, the requirements for the former are tightened.
The changes in the amnesty programs reflect the new IRS approach for addressing taxpayers with offshore tax issues. The new approach provides one path for willful taxpayers, with steeper penalties but certainty, and another path for taxpayers who...
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