SECTION 4. TAXPAYERS THAT ARE
Internal Revenue Bulletin 2003-4 · 2026-10-03 edition · updated 2026-10-04 · United States
ELIGIBLE TO PARTICIPATE IN THE OFFSHORE VOLUNTARY COMPLIANCE INITIATIVE
.01 A taxpayer that has used offshore payment cards or offshore financial arrangements is eligible to participate in the Offshore Voluntary Compliance Initiative if the taxpayer meets the following conditions:
(1) the taxpayer’s written request to participate in the Offshore Voluntary Compliance Initiative is received before :
(a) the Service has initiated a civil examination or criminal investigation of the taxpayer, or has notified the taxpayer that it intends to commence such an examination or investigation;
Offshore Voluntary Compliance Initiative
Rev. Proc. 2003–11
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