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    August 2016
 
           
FEATURED ARTICLE
The Complex Universe of Passive Foreign Investment Companies
By Richard Tannenbaum and Mark Tadros

The passage of the Foreign Account Tax Compliance Act (FATCA) in 2010 signaled a renewed focus by the Internal Revenue Service (IRS) on non-compliance of U.S. taxpayers with ownership of foreign accounts and assets. As part of an initiative to encourage taxpayers with undeclared foreign assets to come forward, the IRS continued and expanded on the original 2009 Offshore Voluntary Disclosure Program (OVDP). The current program offers protection from criminal penalties and a reduction in civil penalties as an incentive for taxpayers to disclose foreign assets when they file past-due or amended tax returns and pay the taxes, interest and penalties on unreported income.
 
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