What does an 'offense' mean for purposes of restitution awards under the VWPA?

QUESTION PRESENTED FOR REVIEW The Victim and Witness Protection Act, 18 U.S.C. § 3663 (“VWPA”), permits a district court to order restitution to victims of an offense under Title 18. A “victim” is a person directly and proximately harmed as a result of the commission of an offense for which restitution may be ordered. “An offense” is not defined, but this Court has held that “the loss caused by the conduct underlying the offense of conviction establishes the outer limits of a restitution order.” Hughey v. United States, 495 U.S. 411, 420 (1990). What does an “offense” mean for purposes of restitution awards under the VWPA? ii