March 14, 2018

On March 13, the I.R.S. announced it will end the Offshore Voluntary Disclosure Program ("O.V.D.P."). Taxpayers with undisclosed foreign financial assets have until September 28, 2018, to enter the 2014 O.V.D.P. and make complete disclosures.

The once-popular program has steadily declined in recent years, with only 600 disclosures last year. The O.V.D.P. was initially launched in 2009 and renewed in 2011, when it reached its peak with 18,000 disclosures. Subsequent versions were released in 2012 and 2014.

Since its launch, more than 56,000 taxpayers have participated in the program and paid over $11 billion in back taxes, penalties, and interest. The close of the O.V.D.P. signals the end of an era with advances in third-party reporting and increased awareness of filing obligations, such as F.B.A.R.'s and F.A.T.C.A., undermining the need for forgiveness programs to encourage taxpayer compliance.

For now, the Streamlined Filing Compliance Procedures will remain available to eligible taxpayers who might not have been aware of their filing obligations. Although, the I.R.S. may terminate it in the future. In addition, the I.R.S. Criminal Investigation Voluntary Disclosure Program, Delinquent F.B.A.R. Submission Procedures, and Delinquent International Information Return Submission Procedures will still be offered to taxpayers to address past noncompliance.

The I.R.S. is urging any remaining taxpayers with undisclosed foreign assets to come forward now.

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