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On January 9, 2012, the Internal Revenue Service (“IRS”) announced a third voluntary disclosure program (“OVDP”) designed to bring offshore money back into the U.S. tax system and to help people with undisclosed income from hidden offshore accounts become current with their taxes
The Foreign Account Tax Compliance Act (“FATCA”), enacted in 2010 as part of the Hiring Incentives to Restore Employment (“HIRE”) Act, added section 6038D to the Internal Revenue Code
