ovdi – Page 8 – Tax Law Center Blog

“Willfulness” When Deciding Whether to Opt Out of 2011 OVDI

11 July, 2011

The IRS recently posted guidance in its OVDI FAQs (#51) whether taxpayers should opt out of the 2011 Voluntary Disclosure Initiative’s (the “OVDI”) civil penalty structure. Taxpayers who participate in the OVDI, but feel that their

Read More

Numerous Criminal Prosecutions of Taxpayers with Unreported Offshore Accounts

1 June, 2011

The Department of Justice and local United States Attorneys’ Offices continue to zealously prosecute numerous cases involving U.S. taxpayers who have failed to report their interests in offshore accounts. The successful prosecutions underscore the government’s

Read More