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200311, to participate in the OVCI, a taxpayer (directly, or through an authorized representative) must formally notify the IRS of the intention to participate and provide identifying information and information about how the taxpayer came to be involved in offshore arrangements or foreign credit or payment cards.
The taxpayer will be required to enter into a formal closing agreement for the tax years submitted under the OVCI. (21)
The OVCI is well-conceived, noble in purpose, and practitioners should conclude it will therefore be administered fairly.
Clearly, a taxpayer who seeks the benefits of the OVCI and enrolls only for 1999-2001, can have prior years subjected to examination and/ or investigation.
The requirement to file amended income tax returns in the OVCI includes not only correcting offshore return aspects, but all other errors and omissions.
There is authority supporting the notion that a participant can be denied OVCI benefits if the IRS collection processes (offer in compromise or installment payment) are not engaged in good faith.
For taxpayers who do not apply, are not accepted into the OVCI, or cannot apply because its requirements are not met (see above), previously extant perils continue, and tax prosecution peril may be never ending.
Taxpayers not eligible for the OVCI may proceed under the general "voluntary disclosure practice." Nothing close to amnesty is available in that process.
For taxpayers having illegal source income and thus not participating in the OVCI, another set of perils is engendered.
More states will likely offer similar treatment to OVCI applicants.
Taxpayers had until April 15, 2003 to apply to participate in the OVCI. Launched in mid-January, it was aimed at individuals who used offshore payment cards or other offshore financial arrangements to avoid U.S.
--The university has officially opened the Rehabilitation Center for Children with Physical and Mental Handicap established by OVCI.
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- Ovcharov, Georgi
- Ovchina-Obolenskii-Telepnev, Ivan
- Ovchina-Obolenskii-Telepnev, Ivan Fedorovich
- Ovchinnikov, Andrei
- Ovchinnikov, Andrei Afanasevich
- Ovchinnikov, Iurii
- Ovchinnikov, Iurii Anatolevich
- Ovchinnikov, Lev
- Ovchinnikov, Lev Nikolaevich
- Ovda, Israel