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The Offshore Voluntary Disclosure Program Is Closing Down

The Offshore Voluntary Disclosure Program Is Closing Down

Author: James F. McDonoughDate: May 15, 2018

The Offshore Voluntary Disclosure Program (OVDP) closes September 28, 2018 and account holders that fail to disclose offshore accounts will be investigated by IRS and DOJ. What is surprising is that the public underestimates the efforts of our government to assemble data and the amount of usable information it now has in its hands. Consider the following story.

There is an organized group in France called “Accidental Americans” comprised of 10,000 or more individuals who acquired U.S. citizenship, typically by being born in the U.S., who left America and live in France. One individual was born in California while his French father was on assignment. His family returned to France when he was four months old and he never returned to the US and he does not speak English. He has never had a U.S. social security number, is of modest means, has no U.S. assets and pays tax in France as a citizen. Because the U.S. taxes citizens on a worldwide basis, this individual has unfiled tax returns for many years and may or may not owe taxes. He is not alone. The IRS dragnet has identified all of these persons. To be fair, it is impossible to tell a tax cheat from an Accidental American on a computer screen without some inquiry. Why does this matter at all you ask?

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