File By Deadline
As previously reported, the IRS has announced that the offshore voluntary disclosure program (OVDP) will be closing on September 28, 2018. The program, which began in 2009, only had 56,000 taxpayers who used one of the programs to comply voluntarily. This is an underwhelming number of taxpayers. Indeed there were only 600 disclosures in 2017. What does that mean?
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The Way It's Been...
Since 2009, the IRS criminal investigation unit has investigated 1545 taxpayers on criminal violations related to international activities, of which 671 were indicted on international criminal tax violations.
The IRS is now sending a clear signal that rather than relying on the voluntary disclosure program it will increase criminal prosecutions to effect compliance. Those who have not complied should heed this warning and file a disclosure before the deadline or otherwise face criminal prosecution!