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Client Alerts

Last Call for Voluntary Disclosures: I.R.S. Announces O.V.D.P. Will End September 28

Last Call for Voluntary Disclosures: I.R.S. Announces O.V.D.P. Will End September 28

On March 13, the I.R.S. announced it will end the Offshore Voluntary Disclosure Program ("O.V.D.P."). Taxpayers with undisclosed foreign financial assets have until September 28, 2018, to enter the 2014 O.V.D.P. and make complete disclosures.

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I.R.S. Imposes Strict Response Times to I.D.R.'s for Large Business and International Taxpayers

I.R.S. Imposes Strict Response Times to I.D.R.'s for Large Business and International Taxpayers

On November 4, 2013, the Large Business and International Division ("LB&I") issued a new directive (“Directive”) providing that an agent generally has no discretion in respect of deadlines for responses to information document requests ("I.D.R.'s"). Due to this Directive, taxpayers subject to this Directive are encouraged not to procrastinate in responding to an I.D.R. The new directive is effective beginning January 2, 2014.

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