IRS to End Offshore Voluntary Compliance Program September 28, 2018

On September 4, 2018, the Internal Revenue Service issued a reminder that taxpayers with undisclosed foreign financial assets have until September 28, 2018, to file a disclosure under the Offshore Voluntary Disclosure Program (OVDP).   The OVDP launched in 2009 as a means for taxpayers to voluntarily past noncompliance related to unreported foreign income or foreign financial assets and failure to file foreign information returns, such as the FBAR.  Since 2009, more than 56,000 taxpayers have...

IRS OVDP To Shut Down in September

The IRS has announced that it will shut down the Offshore Voluntary Disclosure Program (OVDP) on September 28, 2018. The OVDP, which started in 2009, allows taxpayers to voluntarily disclose offshore bank accounts and assets that were not originally reported on their tax returns and Reports of Foreign Bank & Financial Accounts (FBARs). Thousands of U.S. taxpayers have used the program in recent years to report their assets to the IRS, paying civil penalties in exchange for amnesty from crimi...

U.S. Government Continues Suit vs. Taxpayer With Unreported Offshore Bank Accounts

The U.S. government is moving forward in its lawsuit against a U.S. taxpayer accused of a willful failure to disclose offshore bank accounts. In Washington State district court, a judge denied the taxpayer, Jeffrey P. Pomerantz’s, motion to dismiss the case, instead ruling that the government had provided sufficient factual evidence to support a “reasonable inference” that Mr. Pomerantz was liable of a willful failure to report accounts he controlled in Canada and Switzerland during tax years 20...

IRS Announces OVDP Success

Today, the Internal Revenue Service (IRS) is drawing attention to the success of its efforts in bringing taxpayers with unreported offshore accounts back into tax compliance. Since 2009, around 100,000 U.S. taxpayers have utilized the IRS Offshore Voluntary Disclosure Program (OVDP) and its streamlined counterpart to report previously undisclosed foreign accounts, allowing the IRS to collect an approximate $10 billion in taxes, interest and penalties. The passing of the Foreign Account Tax Compl...

Ex-UBS Banker Advocates for Whistleblower Protections

Former UBS banker turned whistleblower Bradley Birkenfeld has called for changes in the Swiss law to protect whistleblowers, as detailed in a recent interview with Bloomberg BNA. Birkenfeld was awarded $104 million in 2012 by the U.S. government for testifying about Swiss bank UBS’s asset protection programs for U.S. taxpayers. His testimony led to wide-ranging probes by the U.S. government into UBS’s activity and culminated in the collection of more than $5 billion in penalties by the U.S. gove...