Feedback: OVDP Part III Offshore Voluntary Disclosure Form 14454

IRS Offshore Voluntary Disclosure Program (OVDP) and Streamlined Process Forms Request for Feedback.


The IRS asked for feedback on many of its current and proposed OVDP and Streamlined Process forms. In the video immediately below, we describe our suggested improvements to OVDP Form 14454, Attachment to Offshore Voluntary Disclosure Letter. Here is the text of the letter we sent in support of our proposed changes to OVDP Form 14454:


October 7, 2015

Internal Revenue Service
Attn: Christie Preston
Room 6129
1111 Constitution Ave. NW
Washington, DC 20224

RE: Comment from FR Doc. No: 2015-19521: Form 14454, Attachment to Offshore Voluntary Disclosure Letter, OMB Number: 1545-XXXX or OMB Number: 1545-2241 (see Para. 3 below)


Dear Ms. Preston:

We are responding to the Department of the Treasury’s request for Comment on its request for OMB approval on the above-referenced form, associated with the IRS’s Offshore Voluntary Disclosure Program.

We have attempted to segregate our response into the categories of comments requested in the notice in the Federal Register.

There was an issue with this form, though. The Form 14454 that was sent to our office by Mr. R. Joseph Durbala, when we requested the versions of the forms for which approval was being sought, indicates that it was last revised January 2013 and is not the same form which is currently being used which was last revised July 2014. We have assumed that the correct version of the form for which comment is being sought is the July 2014 version currently in use.

(c) Ways to enhance the quality, utility, and clarity of the information to be collected:

Line 2 requests that taxpayer enter the “Country, including address, where the account was established”. This question could more clearly be written as “Address, including country, where the account was established.”

Line 10e. requests that a taxpayer list the financial institution (complete with location), the name on the account, the amount of the transfer, and the date of transfer for any deposits to the foreign financial account for which the Attachment is being prepared that were made by funds transferred from other financial institutions. For taxpayers who frequently interacted with multiple different accounts, there would be several transfers which would need to be listed. We would recommend having these questions be in a form where the person completing the form could have multiple different lines of this information to accommodate multiple different transfers. This could be done by re-organizing the fields to be filed into a table and allowing for additional rows to be added (like on the Form 14453, Penalty Computation Worksheet).

We have the same comments for Line 11e as we did for Line 10e. Line 11e also contains a typographical error where is repeats the same language as was listed in Line 10e. Line 11e should be revised to read “If funds were transferred to other financial institutions, provide the following information:” (emphasis added).

It is unclear what Line 12d is requesting. Perhaps a better wording would be “Provide the following information about the Financial Institution in the United States to which the funds were transferred” if that is what is being requested here.

There appears to be a typographical error on the Privacy Act and Paperwork Reduction Notice. The last sentence in the first paragraph of this section states “If you chose to apply, however, you are required to provide all the information requested on the foreign account or asset statement” (emphasis added). Since this line is on the Form 14457, Offshore Voluntary Disclosure Letter, and far more documents are requested than the foreign account or asset statement, it is our assumption that this line is meant to read “If you chose to apply, however, you are required to provide all the information requested on the attachment to offshore voluntary disclosure letter” (emphasis added).

We thank you for your consideration of this information and we would be happy to provide any additional information or feedback should such be needed or beneficial to this process.


Michelle D. Wynn, Esq.

Parent & Parent LLP

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