Posts Tagged ‘2009 OVDP’

The Government Accountability Office was asked to review the Internal Revenue Service 2009 Offshore Disclosure Program and issue a report on its findings.  The report, IRS Has Collected Billions of Dollars, but May be Missing Continued Evasion, GAO-13-318 (March 27, 2013), can be found here.  The report describes the nature of the noncompliance of taxpayers who participated in 2009 OVDP and addresses the extent to which the IRS has used the 2009 OVDP to battle taxpayer noncompliance in failing to file the FBAR and declare offshore income.  It also discusses the IRS’ continued efforts to bring noncompliant taxpayers into the U.S. taxing system.

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The IRS has been accepting information from taxpayers who participated in the 2009 Offshore Voluntary Disclosure Program (“2009 OVDP”) to support a reduction in the 20% penalty they paid with their submissions or their closing statements (Form 906) if the facts of their case satisfy the 5% penalty outlined in the 2011 Offshore Voluntary Disclosure Initiative (“2011 OVDI”).  This reduced 5% penalty (5% of the highest aggregate balance of the taxpayer’s offshore accounts for the program years) was not available in the 2009 OVDP.

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In April and August of 2011, we published alerts on the 2011 Offshore Voluntary Disclosure Initiative (“2011 OVDI”) offering eligible taxpayers a uniform, streamlined and predictable process permitting them to come into compliance with United States income tax laws concerning offshore accounts and offshore entities. The 2011 OVDI followed the IRS 2009 Offshore Voluntary Disclosure Program (“2009 OVDP”) and provided a detailed form of guidance in a question and answer publication (“2011 Q and A”). Fast forward to 2012, where, on January 9, the IRS announced its third initiative in this arena, the 2012 OVDP. To read the rest of the alert, click here (PDF).