201410.02
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IRS OVDP Transition – Can I Switch Over to the Streamlined Program?

Most likely, the answer is no. OVDP Transitions are not very common, and are very limited in scope. They are based on the idea that a person has already submitted to OVDP (not signed the closing letter) but now wants to go Streamlined instead. The most important threshold requirement (other than proving non-willfulness), is timing….

201409.30
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IRS Offshore Disclosure – Highest vs. Year-End Balance Calculations

This article will summarize OVDP (Highest-Year Balance) vs. Streamlined (Highest “Year-End” Balance). Once a person comes to the realization that they are going to submit to OVDP IRS Offshore Voluntary Disclosure Program and pay an upfront penalty in order to leverage against a possible much larger penalty in the future (or Opt-Out), they must determine…