By Patrick McCormick ( December 12, 2018, 3:23 PM EST) -- On Nov. 20, 2018, a memorandum[1] was circulated by the Internal Revenue Service containing updates to their long-standing voluntary disclosure practices. The modifications made follow the termination of the long-standing offshore voluntary disclosure program, or OVDP, with the memorandum interpreted by many practitioners as the IRS' attempt to create a type of "replacement" program for the OVDP. The updates to the IRS' disclosures practices contained in the memorandum formalize a traditionally informal disclosure process, directly address offshore assets and, in some relatively narrow circumstances, can provide the optimal route for an offshore disclosure. However, more palatable offshore disclosure options will likely exist for the significant majority of noncompliant taxpayers with foreign holdings....