Analysis

IRS Could Replace Offshore Voluntary Disclosure Program

Law360, Los Angeles (April 10, 2018, 3:46 PM EDT) -- With the IRS Offshore Voluntary Disclosure Program coming to a close in September, willful violators who do not use the program could face penalties of at least $100,000 or up to half of their foreign accounts for certain misconduct, but it is possible the agency may create a replacement program in the future.

The Internal Revenue Service announced on March 13 it would begin to wind down the 2014 Offshore Voluntary Disclosure Program, which allows U.S. taxpayers who have not disclosed foreign bank accounts either willfully or nonwillfully to come forward while avoiding certain civil and criminal penalties. Acting IRS Commissioner...

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