New Offshore Voluntary Disclosure Program: a Carrot Without a Stick?

, New York Law Journal


In his Tax Litigation Issues column, Jeremy H. Temkin, a principal in Morvillo, Abramowitz, Grand, Iason, Anello & Bohrer, writes that while measured against reports that there were as many as 52,000 accounts at UBS alone, it is difficult to view the 33,000 voluntary disclosures under the 2009 OVDP and the 2011 OVDI as an unqualified success, though they did result in $5 billion in revenue.

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