New IRS Offshore Voluntary Disclosure Program and Related Procedures

Compliance Options for Foreign Assets in a Transparent World

September 23, 2014

Gideon Rothschild

Gideon Rothschild will moderate a panel discussion of the Offshore Voluntary Disclosure Program sponsored by the American Bar Association Section of Real Property, Trust and Estate Law, of which he is Chairman.

On June 18, 2014, the IRS announced substantial changes to its Offshore Voluntary Disclosure Program (OVDP). Taxpayers who have failed to report interests in foreign assets now have three different paths available to them to come into compliance: OVDP, streamlined filing, and delinquent FBAR/information return procedures. Each path has its advantages and disadvantages, and taxpayers may not satisfy requirements necessary to follow certain paths. As such, taxpayers will rely on their attorneys to guide them through the process of coming into compliance. This E-CLE is intended to inform practitioners of the changes to the OVDP, explain potential strategies, discuss potential traps for the unwary, and review lessons learned since the first OVD.


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