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IRS unveils guidance to its Large Business & International and Small Business/Self-Employed divisions setting forth the penalty framework for closing agreements with taxpayers who voluntarily disclose their offshore assets to IRS through a special program. The memorandum follows the agency's Feb. 18 unveiling of the program, its second in this area. In the new memorandum, IRS says cases would be worked by agents who specialize in offshore examinations. The guidance stresses an eight-year lookback period, and says no reasonable cause exceptions would be allowed.
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