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In light of the IRS’s new streamlined procedure for bringing the delinquent tax returns of US persons current, many taxpayers who are currently in the 2009 Offshore Voluntary Disclosure Program (OVDP) or 2011 Offshore Voluntary Disclosure Initiative (OVDI) are considering opting out of these amnesty programs in the hope of filing under the new procedure.

As the world becomes increasingly interconnected and tax laws become more onerous, tax authorities around the world, including the Canada Revenue Agency (CRA), are highly motivated to collect taxes from taxpayers with foreign assets.