On November 20, 2018, the IRS published an Interim Guidance Memo concerning voluntary disclosures, captioned “Updated Voluntary Disclosure Practice” (http://bit.ly/2UHHdLm). The memo sets forth the…
The IRS's streamlined filing procedures for offshore assets were announced in 2012 for non-U.S. residents and extended to U.S. residents in 2014. The streamlined procedures…