In a recent Law360 article, “IRS Could Replace Offshore Voluntary Disclosure Program,” Gabby Hirz comments on the pending closure of the IRS Offshore Voluntary Disclosure Program (OVDP), which allows U.S. taxpayers who have not disclosed foreign bank accounts to come forward while avoiding criminal penalties and paying a reduced civil penalty. Gabby observes that the IRS’s request for comments has caused speculation as to whether IRS is developing a new version of the OVDP. To read more observations from Gabby, please click here.