IRS Offshore Voluntary Disclosure Program Will End on September 28, 2018

By: Randall P. Andreozzi, Esq.

The IRS announced on Wednesday that it will officially end the 2014 Offshore Voluntary Disclosure Program (affectionately known to practitioners as the “OVDP”) on September 28, 2018. The Agency urged taxpayers who still have not come forward to do so before the program ends.

The 2014 OVDP is the last evolution of the program IRS initiated in 2009, and then updated in 2011 and 2012.  The 2014 OVDP remained open ended, with the IRS cautioning taxpayers that the opportunity would not be open forever.  The IRS made good on its promise, and the OVDP will now shut down on September 28.

Over the years, the OVDP, in its various iterations, facilitated disclosures by more than 56,000 taxpayers and generated more than $11 billion in tax, penalties and interest for IRS.

The end to the OVDP is by no means a signal that IRS intends to back off from its aggressive pursuit of those who fail to report their foreign bank accounts.  It is, in fact, quite the opposite.  The IRS, emboldened by the enhancements and advances in third-party reporting through FATCA and its many agreements with foreign governments and foreign financial institutions, fully intends to pursue those individuals and entities still waiting in the weeds with its ever-improving information-gathering and document analysis tools.  The IRS intends to make use of its Criminal Investigation Division and the Whistleblower Program to supplement the investigatory efforts of its civil Revenue Agents.

The IRS will continue to implement its Foreign and Domestic Streamlined Voluntary Disclosure Programs, Delinquent FBAR Submission Protocol, Delinquent International Information Return Submission Procedures, and the traditional IRS Criminal Investigation Voluntary Disclosure Program as methods for taxpayers to come forward to disclose their accounts.  Each of these avenues presents opportunities and possible hazards for individuals and entities who wish to come forward outside of the OVDP or after the OVDP terminates.

Andreozzi Bluestein works with accounting firms around the world to assist taxpayers with respect to the voluntary disclosure of their ownership in foreign bank accounts or other foreign financial assets.

 

Disclaimer

This communication is for general informational purposes only which may or may not reflect the most current developments. It is not intended to constitute legal advice or a recommended course of action in any given situation. This communication is not intended to be, and should not be, relied upon by the recipient in making decision of a legal nature with respect to the issues discussed herein. The recipient is encouraged to consult an independent licensed attorney before making any decision or taking any action concerning the matters in this communication. This communication does not create an attorney-client relationship between Andreozzi Bluestein LLP and the recipient.

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