OVDP Opt-Out or the IRS Streamlined Program – What’s the Difference?

OVDP Opt-Out or the IRS Streamlined Program – What’s the Difference? by Golding & Golding OVDP Opt-Out or the IRS Streamlined Program – What’s the Difference? Recently, we spoke with a client who believed they had received OVDP advice from an experienced international tax lawyer. In speaking with the client, she explained to us that the prior attorney told the client that she should enter OVDP and then opt-out instead of entering the Streamlined Offshore Disclosure program – since it is the same thing except under OVDP, the person receives protection from criminal prosecution, with the reduced penalty. Not only is this analysis incorrect (The IRS can also Increase the penalty under Opt-Out Procedures), but it could lead an individual who is otherwise non-willful and qualifies for the streamlined program stuck in OVDP — with intense fines and penalties if the opt-out does not go properly. OVDP Opt-out vs. Streamlined At the current…

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