To those reading here who are in the OVDI, I draw your attention to this Jack Townsend guest post by Asher Rubinstein, Esq.
It has been said that the 2011 Offshore Voluntary Disclosure Initiative (OVDI) corrected many of the hiccups of the 2009 Offshore Voluntary Disclosure Program (OVDP)…… However, as more OVDI cases now head toward resolution, it appears that the IRS is again wavering in certain policy decisions, again to the detriment of taxpayers.
Why am I not surprised by this?