Morison Cogen LLP

Accounting, Audit & Tax Services

Client Portal | Secure Upload267.440.3000

  • Home
  • About Us
    • What We Do
    • Why Choose Us
    • Partners
    • Managers
    • Partners Emeritus
  • Services
    • Accounting
    • Audit
    • Tax
    • Financial Management
  • News and Posts
    • Business
    • Employer
    • ETRA
    • Federal Tax Posts
    • Individual Tax
    • Not for Profit
    • Small Business Tax
    • Featured
  • Contact Us Today
    • Join Our Mailing List
  • Morison Global

March 16, 2018

Offshore Voluntary Disclosure Program (OVDP) – Program to close on September 28, 2018

Yesterday, the Internal Revenue Service released Internal Revenue Notice 2018-52, in which it announced it would begin to ramp down the 2014 Offshore Voluntary Disclosure Program (OVDP) and close the program on Sept. 28, 2018.
If you have undisclosed foreign financial assets, time is running out to get into compliance.

The full text of IR-2018-52 follows:
WASHINGTON – The Internal Revenue Service today announced it will begin to ramp down the 2014 Offshore Voluntary Disclosure Program (OVDP) and close the program on Sept. 28, 2018. By alerting taxpayers now, the IRS intends that any U.S. taxpayers with undisclosed foreign financial assets have time to use the OVDP before the program closes.
“Taxpayers have had several years to come into compliance with U.S. tax laws under this program,” said Acting IRS Commissioner David Kautter. “All along, we have been clear that we would close the program at the appropriate time, and we have reached that point. Those who still wish to come forward have time to do so.”
Since the OVDP’s initial launch in 2009, more than 56,000 taxpayers have used one of the programs to comply voluntarily. All told, those taxpayers paid a total of $11.1 billion in back taxes, interest and penalties. The planned end of the current OVDP also reflects advances in third-party reporting and increased awareness of U.S. taxpayers of their offshore tax and reporting obligations.
The number of taxpayer disclosures under the OVDP peaked in 2011, when about 18,000 people came forward. The number steadily declined through the years, falling to only 600 disclosures in 2017.
The current OVDP began in 2014 and is a modified version of the OVDP launched in 2012, which followed voluntary programs offered in 2011 and 2009. The programs have enabled U.S. taxpayers to voluntarily resolve past non-compliance related to unreported foreign financial assets and failure to file foreign information returns.

Tax Enforcement
The IRS notes that it will continue to use tools besides voluntary disclosure to combat offshore tax avoidance, including taxpayer education, Whistleblower leads, civil examination and criminal prosecution. Since 2009, IRS Criminal Investigation has indicted 1,545 taxpayers on criminal violations related to international activities, of which 671 taxpayers were indicted on international criminal tax violations.
“The IRS remains actively engaged in ferreting out the identities of those with undisclosed foreign accounts with the use of information resources and increased data analytics,” said Don Fort, Chief, IRS Criminal Investigation. “Stopping offshore tax noncompliance remains a top priority of the IRS.”

Streamlined Procedures and Other Options
A separate program, the Streamlined Filing Compliance Procedures, for taxpayers who might not have been aware of their filing obligations, has helped about 65,000 additional taxpayers come into compliance. The Streamlined Filing Compliance Procedures will remain in place and available to eligible taxpayers. As with OVDP, the IRS has said it may end the Streamlined Filing Compliance Procedures at some point.
The implementation of the Foreign Account Tax Compliance Act (FATCA) and the ongoing efforts of the IRS and the Department of Justice to ensure compliance by those with U.S. tax obligations have raised awareness of U.S. tax and information reporting obligations with respect to undisclosed foreign financial assets. Because the circumstances of taxpayers with foreign financial assets vary widely, the IRS will continue offering the following options for addressing previous failures to comply with U.S. tax and information return obligations with respect to those assets:
• IRS-Criminal Investigation Voluntary Disclosure Program;
• Streamlined Filing Compliance Procedures;
• Delinquent FBAR submission procedures; and
• Delinquent international information return submission procedures.
Full details of the options available for U.S. taxpayers with undisclosed foreign financial assets can be found on IRS.gov.

If you have undisclosed foreign financial assets, or think you may, give us a call to discuss your options under the Offshore Voluntary Disclosure Program.

Filed Under: Featured

Recent News and Posts

Tax-saving ways to help pay for college — once your child starts attending

SECURE 2.0 law may make you more secure in retirement

Do you qualify for the QBI deduction? And can you do anything by year-end to help qualify?

Renting to a relative? Watch out for tax traps

2023 tax calendar

News and Posts by Category

  • Business
  • Employer
  • ETRA
  • Featured
  • Federal Tax Posts
  • Individual Tax
  • Not for Profit
  • Small Business Tax
  • tax
  • Tax Tips

Items of Interest

Merger Announced!

Morison Global Press Release

Tax Planning Guide

Global Tax Insights

Peer Review Letter

CPA-USA Association

Join Our Mailing List

About Morison Cogen

Morison Cogen LLP is a full-service certified public accounting, tax, and business consulting firm serving private and public companies, not-for-profit organizations, and the personal accounting needs of individuals in the U.S. and around the world....read more

Get Connected

Morison Cogen LLP
484 Norristown Road, Suite 100
Blue Bell, PA 19422

P: 267.440.3000
F: 267.440.3001
E: info@morisoncogen.com

Copyright © 2023 Morison Cogen LLP