On March 13, 2018 the Internal Revenue Service (“IRS”) announced on its Notice 2018-52 that it will begin to ramp down its amnesty program under the Offshore Voluntary Disclosure Program (OVDP) and close the program on September 28, 2018.
The current OVDP started in 2012 and it was later modified in 2014. It allows US taxpayers to voluntary disclosure unreported foreign income and foreign bank accounts, as well as other financial assets and unreported foreign information returns.
The Streamlined Filing Compliance Procedures, a similar but different version of the Offshore Voluntary Disclosure Program, will remain in place for now. However, the IRS has stated that the end of OVDP is likely to happen at some point in the future. The delinquent FBAR submission procedures and delinquent international information return submission procedures are also to remain open for the time being.
US citizens and resident aliens with foreign income and foreign financial assets must report them on their Annual Income Tax Return and must file form FinCEN 114, also known as FBARs.
U.S. taxpayers who have undisclosed foreign financial assets can find relevant information on the options that are available to them here.
For those who have failed to comply with the rules, we urge that you talk to an experienced international tax attorney to assist you filing for one of the available programs to avoid hefty penalties in case of an investigation or audit by the IRS. The tax professionals at Brunoro Law are experienced in the matter and can assist you throughout the entire process.