Tax Notes Article by Jeremiah Coder: "No Traditional Disclosure Practice Allowed for Offshore Cases, IRS Officials Say."

Tax Notes Today has published an article by Jeremiah Coder, an attorney and contributing editor to Tax Analysts. The article discusses recent statements made by IRS counsel that taxpayers disclosing offshore accounts will be evaluated under the "offshore voluntary disclosure initiative" and cannot opt for the traditional IRS voluntary disclosure program. The article also discusses the recent realignment of practice groups under the IRS Large Business and International Division, and it confirms that the IRS's SB/SE division will continue audits on high-net-worth individuals.