“The Geneva-based international group says that the 2009 OVDP in particular was ‘extremely prejudicial to Americans living overseas who sought to become compliant with their taxes due to errors or omissions under the OVDP. Believing they could come back into the system by simply filing the appropriate paperwork and paying any outstanding tax burden, these individuals were later told they would be hit with a standard penalty of 20% of the highest value of their bank accounts over a five-year period.'”
http://genevalunch.com/2013/06/04/irs-systematically-targeted-overseas-americans-update/
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