To OVDI or not to OVDI - Part 2 (7/31/11)

I write today on the analytic process I use in stepping through with clients their consideration of their decision whether (i) to OVDI or not to OVDI and (ii) if OVDI is chosen, whether to opt out.

I assume a simple fact pattern (set forth below) to illustrate the process.  My discussion does not deal with complex fact patterns.  With more complex fact patterns, a similar analytic process can be used but the process must then deal with the complexities which make conclusions harder to draw. Whether complex or not, the analytic process is not for the faint-hearted or risk-averse or for clients who do not have experienced counsel to make the judgment calls required by the procss. Hence I write this blog principally to generate discussion among tax professionals who are readers of this blog. I caution readers who are not tax professionals to seek individualized help from tax professionals before implementing any strategy they think they may perceive in this blog.
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