On June 18, the IRS announced changes to two programs previously
established to bring taxpayers into compliance with reporting and
payment obligations related to offshore assets. Participation
in either of the two programs – the 2012 Offshore Voluntary
Disclosure Program, and the "streamlined filing compliance
procedures" announced in 2012 – can secure treatment by
the IRS that is much less onerous than treatment which could result
if the taxpayer has not come forward before the IRS discovers the
taxpayer's past noncompliance. However, it is critical for
taxpayers to consult counsel, and time is of the essence.
On June 18, 2014, the IRS announced "a number of important
changes to its offshore account compliance programs."
The changes include reshaping the terms of the 2012 Offshore
Voluntary Disclosure Program (OVDP) and expanding the streamlined
filing procedures. The IRS believes that these important changes
"will lead to a significant increase in the number of
