Today the Internal Revenue Service released its long-awaited updated procedures for voluntary disclosures now that the much-heralded Offshore Voluntary Disclosure Program (OVDP) closed on September 28, 2018. The updated procedures apply to all voluntary disclosures (both domestic and offshore) received by the IRS after the closing of the OVDP. IRS-Criminal Investigation will continue to screen all voluntary disclosures through the preclearance process, with the IRS LB&I office in Austin, Texas, continuing to process, and examine, tax returns. Most importantly, the updated procedures contain a new “Civil Resolution Framework” which addresses the scope of future voluntary disclosures and a new penalty structure. In subsequent posts we will provide detailed analysis of these newly-updated voluntary disclosure guidelines.
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