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Scott Michel Quoted in Tax Notes, IRS Revising FAQ for Offshore Voluntary Disclosure Program

June 25, 2012, Tax Analysts
Excerpt taken from the article.

The IRS is seeking to revise and clarify frequently asked questions on its latest iteration of the offshore voluntary disclosure program (OVDP) to respond to inquiries submitted by practitioners and tax-payers, an IRS official said June 15. 

The upcoming FAQ will likely clarify the rolling eight-year period of returns due with the voluntary disclosure, said Jennifer Best, IRS senior attorney-adviser (services and enforcement), at New York University's annual Tax Controversy Forum. "If the return is not yet due for a year, then that year is not included in the eight-year period," she said. The IRS also plans to clarify that compliant years' returns are not due as part of the disclosure, she said.

Scott D. Michel of Caplin & Drysdale said one area of confusion for practitioners had been how far back returns were due for taxpayers who were new to the program.

Click here to read the entire article on IRS Revisions to the Offshore FAQs.

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