December 2016 JD Supra

Through its Offshore Voluntary Disclosure Program (OVDP), IRS permits noncompliant taxpayers to disclose Willfully unreported offshore accounts and related income. The “key” word for OVDP is Willful. Unlike the Streamlined Filing Compliance Procedures, program which is intended for Taxpayers that have acted Non-Willfully, OVDP encourages Taxpayers who have acted Willfully to immediately disclose through OVDP to eliminate risk of IRS detection and the possibility of criminal prosecution.

http://www.jdsupra.com/legalnews/do-you-know-why-and-how-to-make-an-79692/