On Jan. 9, 2012, the Internal Revenue Service announced the opening of its third offshore voluntary disclosure program for taxpayers with unreported foreign accounts who seek to come into compliance with their U.S. reporting obligations. This third program follows on the heels of the first two, which have collected over $4.4 billion from more than 33,000 taxpayers in the past three years. The first two programs were initiated in 2009 and 2011...
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