IRS OVDP for corporations and other entities, domestic or offshore

IRS OVDP for corporations and other entities, domestic or offshore

That was a stat given to me by an OVDI examiner back in 2010. She told me that the IRS believed that 70% of unreported foreign accounts were held in the name of corporations, partnerships, trusts, llcs, and foundations, as an additional barrier to avoid detection.

Myself --- I think this number is off. I think the IRS completely miscalculated the amount of innocent minnows who held account in their own name.

In this article I discuss the various paths to compliance for foreign vs. domestic domiciled or registered entities. In other words,  does the individual have to go through OVDP, the entity or both?