End of the OVDP, Streamlined Continues….for now
The IRS has finally announced that the current amnesty option under the Offshore Voluntary Disclosure Program will close on September 28, 2018. As the IRS has collected information through FATCA reporting, many suspected this day was coming. The current OVDP has been open since 2012 and was modified in 2014.
For now, the amnesty programs under the streamlined filing will remain open. However, since these are based on the same FATCA related information, and because other options remain available such as reasonable cause, it is prudent to assume the days are numbered on the streamlined filings as well. Although, it is more likely the IRS would be willing to accept these non-willful offenders into compliance for a longer period than those needing the OVDP. The delinquent FBAR submission procedures and delinquent international information return submission procedures are also to remain open for the time being.
Overall, this does not change the reality of the situation. We have stressed that taxpayers needing to avail themselves of one of the programs should do that as soon as possible because once an investigation or audit is opened it is too late. That is still the recommendation, but now the IRS has set the deadline for at least the OVDP.
- More than 56,000 taxpayers have used one of the amnesty programs to become compliant
- $11.1 billion has been collected in tax, interest, and penalties through the amnesty programs
- Since 2009, IRS Criminal Investigation has indicted 1,545 taxpayers on criminal violations related to international activities
- Of the 1,545 taxpayers indicted, 671 were for international criminal tax violations