IRS Announces End Of Offshore Voluntary Disclosure Program

On March 13, 2018, the Internal Revenue Service ("IRS") announced that the Offshore Voluntary Disclosure Program ("OVDP") will end on September 28, 2018. The program has allowed taxpayers to avoid criminal prosecution by disclosing their unreported offshore activities, filing amended tax returns, and paying tax with reduced penalties. A separate program—the Streamlined Filing Compliance Procedures—was introduced in 2012 for taxpayers who were unaware of their filing obligations and will remain available to eligible taxpayers.

While the OVDP is ending, the Department of Justice and IRS have made clear that taxpayers will continue to be prosecuted for criminal violations: "The IRS remains actively engaged in ferreting out the identities of those with undisclosed foreign accounts with the use of information resources and increased data analytics ... Stopping offshore tax noncompliance remains a top priority of the IRS." The IRS has access to an enormous amount of