Offshore Voluntary Disclosure Program Closing

Offshore Voluntary Disclosure Program (OVDP) Closing

The IRS will formally end its tax amnesty program, Offshore Voluntary Disclosure Program (OVDP), effective September 28, 2018.

According to the IRS, there has been significant decline in participating taxpayers coupled with an increase in awareness of offshore tax and reporting obligations as a result of the Foreign Account Tax Compliance Act (FATCA) and other compliance initiatives.

First launched in 2009, the OVDP was originally established to allow taxpayers to voluntarily report previously undisclosed foreign assets and resolve past noncompliance resulting from failure to report or file returns related to said assets. Since its inception, more than 56,000 taxpayers have leveraged ODVP to comply voluntarily.

MFA Observations
For individual taxpayers looking to participate prior to the program’s end, disclosures must be received prior to the September 28, 2018 deadline and “may not be partial, incomplete, or placeholder submissions”. If you would like to take advantage of this program before it’s completion, please reach out to a member of MFA’s Individual & Family Tax Practice as soon as possible to ensure deadlines are met.Additionally, a separate IRS program, the Streamlined Filing Compliance Procedures, remains in place for taxpayers who wish to certify that previous failures to report foreign assets were not conducted willfully. Per the IRS, the Streamlined Filing Compliance Procedures program – like the OVDP – may be closed at any time.

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