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Entries tagged “internal revenue manual”

IRS Voluntary Disclosure Practice – Internal Revenue Manual Updated Recently

insights December 10, 2020

You may know that the IRS Offshore Voluntary Disclosure Program (“OVDP”) closed, leaving taxpayers who did not fit within the confines of the streamlined programs with scant options for disclosure. As such, anyone who could not certify under penalties of perjury that their failure to report, disclose or pay tax was not willful, was left twisting in the…

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