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IRS announces 2012 voluntary disclosure program, increases penalty rate

The IRS has announced a new voluntary disclosure program for US persons with unreported foreign income. It borrows heavily from the 2011 voluntary disclosure program with two major differences.  First, there is no set deadline for applying under this program although it can be changed or cancelled at any time.  Second, the offshore penalty rate has increased from 25% to 27.5%, though a reduced penalty…

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