Kristina Novak and Laura Gavioli wrote this bylined article about an IRS webinar concerning a campaign targeting inbound distributors and taxpayers not participating in the IRS Offshore Voluntary Disclosure Program (OVDP). As discussed in the webinar, the authors wrote, “this campaign is somewhat unique in that the IRS is still evaluating whether this issue presents an actual—rather than a mere potential—threat of noncompliance.”