Offshore Voluntary Disclosure Program to end in September

By Sally P. Schreiber, J.D.

The IRS announced that it is closing the 2014 Offshore Voluntary Disclosure Program (OVDP) on Sept. 28, 2018. It also said it was announcing OVDP’s closure now so taxpayers with undisclosed foreign accounts who want to participate will be aware that they have to act to take advantage of it.

“All along, we have been clear that we would close the program at the appropriate time, and we have reached that point,” said Acting IRS Commissioner David Kautter in a prepared statement. “Those who still wish to come forward have time to do so.”

The IRS touted the program’s success since it was launched in its original version in 2009, noting that more than 56,000 taxpayers have participated, paying $11.1 billion in back taxes, penalties, and interest. However, the number of taxpayers using the OVDP has declined from a peak of 18,000 people coming forward in 2011 to only 600 in 2017.

The IRS said its efforts to find taxpayers who fail to disclose foreign accounts will continue through the use of taxpayer education, criminal prosecution, civil examinations, and whistleblowers. The IRS reported that since 2009, the IRS Criminal Investigation division has indicted 1,545 taxpayers for criminal violations related to international activities and that it continues to fight offshore tax avoidance. The news release indicated that the Criminal Investigation Voluntary Disclosure Program continues to exist, as do procedures for submitting delinquent FinCEN Forms 114, Report of Foreign Bank and Financial Accounts, and delinquent international information returns.

Taxpayers who were unaware of their filing obligations can continue to use the Streamlined Filing Compliance Procedures, although the IRS said it may end this program as well sometime in the future.

Sally P. Schreiber ( is a Tax Adviser senior editor.

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