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Perspective

Sep. 29, 2011

The sanctuary of the foreign bank account is no more

With its offshore tax compliance initiatives no longer available, the government makes global tax enforcement a top priority. By Nathan J. Hochman of Bingham McCutchen


On Sept. 9, the Internal Revenue Service concluded its second offshore voluntary disclosure initiative (2011 OVDI) targeting taxpayers who wanted to "come in from the cold" and disclose their unreported foreign bank accounts. The 2011 OVDI, like the one that preceded it in 2009, bargained away criminal prosecution and draconian civil penalties in exchange for taxpayers fully disclosing all their offshore accounts, agreeing to pay tax and interest on their offshor...

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