March 2018 JD Supra

On March 13, 2018, IRS announced the termination of the Offshore Voluntary Disclosure Program (OVDP) as of September 28, 2018 (Notice IR-2018-52).  OVDP has been available to Taxpayers that willfully failed to report foreign financial assets and pay all tax due in respect of those assets.  The program (available since 2009) was designed to protect Taxpayers from criminal liability and provide terms and resolution for the Taxpayer’s tax and penalty obligations.