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ARTICLE · 13 FEBRUARY 2011

IRS Likely To Announce New Voluntary Disclosure Program

Withers LLP
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The IRS is preparing to announce a new Voluntary Disclosure (‘VD') program aimed at non-compliant US taxpayers with unreported offshore accounts.

United StatesTax

The IRS is preparing to announce a new Voluntary Disclosure ('VD') program aimed at non-compliant US taxpayers with unreported offshore accounts. The possibility was first raised in December by IRS Commissioner Douglas Shulman and confirmed last week by IRS Deputy Commissioner Steven Miller.

The new VD program would borrow heavily on the terms offered in 2009 under which taxpayers were able to come clean with the IRS to mitigate the risk of criminal prosecution in exchange for paying taxes, interest and a standardized penalty.

Nearly 15,000 voluntary disclosures were made pursuant to the 2009 program. The IRS has reported that another 3,000 disclosures have been made since October 2009, and it appears that those individuals will be processed under the terms of the pending VD program, along with those who come forward currently.

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