On June 18th, 2014, there were major changes implemented by the IRS voluntary disclosure practice, which revised the 2012 Offshore Voluntary Disclosure Program (OVDP) that also paralleled a revision to the Streamline Filing Compliance Procedure.
The big takeaway from this revision is that, instead of having one path to compliance, the IRS now provides several options to taxpayers that are specific to the facts and circumstances of the individual taxpayer.
I will break down this guide into two main headings: (1) Willful Taxpayers and (2) Non-Willful Taxpayers. Under these two main headings, I will further expand the options available under the 2014 Offshore Voluntary Disclosure Program.
The following are being discussed step by step in this guide.
1. Willful Taxpayers
- Offshore Voluntary Disclosure Program (OVDP)
2. Non-Willful Taxpayers
- Streamline Filing Compliance Procedures – Domestic
- Delinquent FBAR Submission Procedures
- Delinquent International Information Return Submission Procedures
Download the Complete Guide (PDF) and review the options the IRS is now providing you with step by step to see which might best fit your situation.
Taxpayers considering any of these fairly involved and complex avenues of compliance should contact an experienced Federally Authorized Tax Practitioner to represent them in these matters.
About Five Stone Tax Advisers
Five Stone Tax Advisers has years of experience negotiating directly with the IRS to get the best possible outcome for you. Our International Tax Advisory and Compliance unit has a team of tax attorneys, certified public accountants and enrolled agents that form a single sourced point of contact that will provide services for all the legal, compliance and financial reconstruction aspects of offshore account cases.