At the very end (fast track Audit) of 2011 OVDI process and the Revenue Agent has taken a position that is unacceptable and in contradiction of the FAQs IMO. Significant financial differences as to penalties are in controversy.
RA insists there is no opt-out, I feel fairly certain there is (and am aware of the alternative and potential good/bad outcomes if opt-out is available and in fact elected).
Called IRS OVDI Hotline and surprisingly the Hotline person said he would have to look into it and get back to me. They are always quite helpful and I eagerly await his response.
Folks with experience with any of the 3 IRS VD programs for Offshore Entities are hereby sought for their thoughts/opinions.
Thanks.
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