The Internal Revenue Service recently announced it will close the Offshore Voluntary Disclosure Program (OVDP) on September 28, 2018.
The IRS news release on the closure of the OVDP stated:
“Since the OVDP’s initial launch in 2009, more than 56,000 taxpayers have used one of the programs to comply voluntarily. All told, those taxpayers paid a total of $11.1 billion in back taxes, interest and penalties. The planned end of the current OVDP also reflects advances in third-party reporting and increased awareness of U.S. taxpayers of their offshore tax and reporting obligations.”
In the announcement, the IRS noted that it will continue to use other tools to combat offshore tax avoidance, including civil and criminal methods. According to the announcement, “[s]ince 2009, IRS Criminal Investigation has indicted 1,545 taxpayers on criminal violations related to international activities, of which 671 taxpayers were indicted on international criminal tax violations.”
The IRS stated it will continue to utilize the Streamlined Filing Compliance Procedures for taxpayers who qualify; however, the Service also indicated it may end the Streamlined Filing Compliance Procedures at some point.
J. Eric Butler is a Shareholder in the firm focusing his legal practice in the areas of federal and state taxation, business formations and commercial litigation, tax controversy matters, white collar criminal defense, and estate planning/probate matters. Mr. Butler handles a large range of tax matters for clients across the United States involving the Internal Revenue Service and state taxing authorities, to include examinations of returns, collection of delinquent tax debts, criminal tax matters, international tax compliance and enforcement, and litigation of tax issues in both state and federal courts. Mr. Butler also represents accountants across the United States in malpractice defense, mitigation of potential malpractice claims, and disciplinary proceedings.
Mr. Butler received a three-year appointment (2013 through 2015) to the Taxpayer Advocacy Panel, which is a federal advisory panel established in 2002 under the authority of the U.S. Department of the Treasury. The Taxpayer Advocacy Panel (TAP) is made up of volunteers appointed by the Secretary of the Treasury to represent all 50 states, the District of Columbia and Puerto Rico. TAP members are assigned to separate Project Committees and include at least one representative from each state. Mr. Butler served on the Tax Forms & Publications Project Committee during his three-year term, which works to provide feedback to Internal Revenue Service on issues involving tax administration and improvements to tax forms and publications. In 2015, Mr. Butler served as Vice-Chair of the Tax Forms and Publications Project Committee. In 2016, Mr. Butler was awarded the President’s Volunteer Service Award for his contributions to TAP during his three-year term.
Mr. Butler is a frequent speaker to various organizations and businesses on issues involving tax law, business law, and estate planning/probate matters.