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On January 9, 2012, the Internal Revenue Service (“IRS”) announced its third Offshore Voluntary Disclosure Program (“OVDP”). This program was modified for submissions after July 1, 2014, but remains part of the 2012 program. The previous OVDPs (the 2011 version was classified as an Offshore Voluntary Disclosure Initiative or OVDI) generated more than $5 billion of collected back taxes, interest and penalties, from more than 33,000 program participants. Individuals and corporations alike were among that group of program participants.