The IRS on June 18 announced long-awaited changes, including
some significant modifications, to the offshore voluntary
disclosure program (OVDP).
The OVDP and its predecessor voluntary compliance initiatives
have been ongoing since 2009, and have served as a way for
taxpayers with undeclared foreign accounts to avoid criminal
prosecution through disclosure and payment of penalties. The IRS
says that in all, more than 45,000 taxpayers have come forward,
paying taxes, interest and penalties of more than $6.5 billion.
The IRS's changes to the OVDP include an expansion of the
streamlined procedures enacted in 2012. That program's
eligibility has been expanded to include U.S. taxpayers residing in
the United States. In addition, the updated program no longer
requires the taxpayer to have $1,500 or less in unpaid tax per year
and eliminates the required risk questionnaire.