"What the OVDP Training Materials Tell US"

There is a brief article in Tax Notes Today based on the FOIA documents, "What the OVDP Training Materials Tell US" by Marie Sapirie, 2014 TNT 230-2 published 12/1/2014:

I was hoping to find memos or guidance as to how some of these decisions were made..... I don't think there's anything in there that comes as a big surprise forthose of us who have done hundreds of these [offshore voluntary disclosures].....Did this taxpayer act like anordinary, reasonable, prudent person?"..... lack of knowledge of the filing requirement is generally not reasonable cause.....one way taxpayers could establish reasonable cause was to show reliance on professional advice.......
"there are legitimate or non-tax motivated reasons [why] a U.S. Taxpayer would engage in offshore transactions.".......The IRS struggled with how to deal with offshore accounts and transactions that were not used for tax fraud, but that had not been reported........"Agents were encouraged to "put themselves in the taxpayer's shoes, understand the motivation for going offshore, and judge the reasonableness of their explanations for a specific transaction in that light.".......

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