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Following the end of the 2014 Offshore Voluntary Disclosure Program (OVDP), the IRS Criminal Division Chief announced a new procedure available to eligible individuals and entities who wish to come into compliance and disclose previously undisclosed foreign assets and income   The new procedure is effective for offshore voluntary disclosures made after September 28, 2018.  The objective of the updated  voluntary disclosure procedure is to provide individuals and entities who are concerned their conduct may be willful or fraudulent, and that may rise to the level of tax and tax-related criminal acts, with a means to come into compliance with the law and potentially avoid criminal prosecution.  Prior to September 28, 2018, these individuals and entities would have utilized the 2014 OVDP to come into compliance, but it has now ended.  The new procedure is not as favorable as the 2014 OVDP, but it may provide significant benefits for those eligible to apply.   For those individuals and entities facing these concerns, the tax attorneys at the Wilson Tax Law Group  are available to assist and can be reached at 949-397-2292.

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