As you may have read, the Internal Revenue Service
("IRS") recently announced changes to its offshore
voluntary disclosure programs and announced new options for
taxpayers to come into compliance with their U.S. tax
obligations.
This alert summarizes some of the significant modifications made
to the program and summarizes the new, expanded Streamlined Filing
Compliance Procedures Program, which is now available for taxpayers
who previously filed U.S. tax returns and for taxpayers who reside
in the U.S. (as long as the other eligibility requirements are
satisfied).
I. Changes to the Offshore Voluntary Disclosure Program (the
"offshore program" or "OVDP")
In many respects, the offshore program remains the same –
generally, taxpayers who participate in the program must submit,
with respect to the prior eight years, amended or delinquent tax
returns, applicable information returns and the Report of Foreign
Bank and Financial Accounts (the "FBAR") and submit
payment
