The Internal Revenue Service will be providing new guidelines to the Offshore Voluntary Disclosure Program (OVDP) which address such issues as the number of years at issue (there has been much debate amongst tax attorneys as to whether it is 3, 6, 8, or more). We also expect it to address issues facing taxpayers who may not have been the intended targets of the program.
We will keep you posted.
In the meantime, contact Moskowitz, LLP for more information.