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The IRS has announced that it will
begin to reduce and eventually eliminate the 2014 Offshore Voluntary Disclosure
Program on 28 September 2018. See IR-2018-52, March 13, 2018.
The IRS urged U.S. taxpayers with undisclosed foreign financial assets to come
forward now before the program closes.
The current program that began in
2014 is a modified version of a 2012 program, which followed earlier iterations
offered in 2011 and 2009. The goal was
to combat evasion of taxes by concealing assets overseas and was coordinated
with various tools the IRS developed to identify foreign assets and tax
evasion, such as FATCA, other new reporting programs, and information-sharing
agreements with many foreign tax authorities. Taxpayers who came forward voluntarily avoided criminal prosecution and
paid reduced civil penalties. Since
2009, over 56,000 taxpayers have used the program, voluntarily paying over
$11.1 billion in back taxes, interest, and penalties.
Disclosures peaked in 2011 and
have steadily declined since. The IRS is
now satisfied that it has adequate tools to find and address tax evaders and
does not need the “carrot” of the voluntary disclosure program. It believes that the closing date of 28
September 2018, will give any taxpayers still wishing to take advantage of the
program plenty of time to do so.
Worldwide ERC® members with
overseas employees will want to remind them of their reporting and filing
responsibilities and advise them that this program to remedy any past
transgressions will expire soon.