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The National Taxpayer Advocate who has intervened for participants in OVDP and perhaps OVDI as well has issued her annual report to Congress. The web page with links to components of the report is here.Among the items discussed are the problems she and her staff perceive with respect to the IRS's implementation of the voluntary disclosure programs for offshore accounts. Most of her specific angst appears directed to the IRS's "bait and switch" on OVDP 2009 FAQ 35. Readers of this blog already know of the bait and switch and the NTA's disapproval. See particularly Tax Notes Discusses Dispute Between the Taxpayer Advocate and the IRS About OVDP 2011 (1/6/12), here. The NTA's comments in the report are contained in the International Issues section here.
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