1. IRS CUTS PENALTIES AND STREAMLINES ITS OFFSHORE DISCLOSURE PROGRAM

    The IRS has announced sweeping changes to its Offshore Voluntary Disclosure Program (Program) for U.S. taxpayers who have previously been noncompliant.  In its 2014 Program effective July 1, 2014, the IRS reduced penalties to 5%, and in some cases to 0%, in the case of taxpayers whose conduct was not willful.  Non-willful conduct includes a failure to disclose due to negligence, inadvertence, a mistake, or a misunderstanding of the law.

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