This is a continuation of Part I. This hypothetical pertains to a taxpayer who has applied to OVDP and who has transferred assets from one foreign account, which was recently closed, to another during the disclosure period.
This is a simple example, yet it illustrates some of the common mistakes that are associated with double counting.
Joe has applied to the OVDP. He had two foreign accounts in 2010: one at Bank A and another at Bank B.
The opening balances in each account were as follows: Read more