On November 20, 2018 and the IRS announced new Offshore Voluntary Disclosure Practice rules. In this article we will outline the significant changes. We also can expect to see clarifications and additional changes, so it is imperative that like all of our content, do not rely upon what you read as legal advice. Everything is subject to change.

The IRS ended its Offshore Voluntary Disclosure Program or OVDP for short, on September 28, 2018. So what does this mean for taxpayers who have not made a disclosure? What should they do now? Are there any options left? In this video, I’ll explain exactly what paths remain open for those worried about FBAR penalties, the myriad foreign reporting penalties, and criminal prosecution.

The IRS ended the 2014 Offshore Voluntary Disclosure Program (OVDP) in September of 2018. leaving the Streamlined and Delinquent Informational Reporting Form (DIRF) programs open. And on November 20, 2018, the IRS announced new Offshore Voluntary Disclosure Practice rules for taxpayers seeking protection from criminal prosecution.

The trickle of IRS Offshore Voluntary Disclosure Program (OVDP) Opt-outs has now developed into a steady stream for us. We have had some incredible successes, but we have also run into frustrations. In this article, I’ll discuss the benefits and drawbacks for those who are considering whether or not to Opt-out of the Standard OVDP 27.5% or 50% penalty.

Last year, Robert, Dennis, and I presented a CLE on “Appealing IRS Penalty Abatement Denials: Offshore Disclosure Penalties, OVDP Denials and Appeals.” There have been a lot of developments since then — both in the court room and internally at the IRS. But one thing hasn’t changed: the IRS is incredibly aggressive, yet inconsistent, about assessing international penalties. We invite any tax practitioners concerned about keeping their international clientele safe from this real and present danger to join us.

Too many people, realizing they have a problem with issing FBARs, Form 8938 and income overseas panic. They go to irs.gov and become convinced that they need to enter into the full Offshore Voluntary Disclosure Program (OVDP) — or else. The problem is that once you go full OVDP, you can’t go back, even if the Streamlined program was the most appropriate choice. In this article we will add some perspective on who should use the full OVDP and those who should use the Streamlined program.

Our work as Offshore Voluntary Disclosure Program (OVDP) attorneys is rewarding. Working with our dynamic clients, getting to know them, their families, while doing our best to mitigate the risk and damage the IRS intend to cause — we feel great because the work we do is incredibly consequential.

The IRS Offshore Voluntary Disclosure Program (OVDP) is not just for individuals. Thanks to a harsh and extensive international tax form penalty regime, there can be a great incentive to enter into an offshore program to cure any of these unfiled or substantially incomplete forms: