On Nov. 29, 2018, the IRS released a memorandum with new procedures for all voluntary disclosures following the end of the Offshore Voluntary Disclosure Program (OVDP) on Sept. 28, 2018. The new voluntary disclosure procedures apply to both domestic and offshore voluntary disclosures.

What’s Changed?

Background

OVDP was initiated in 2009 and designed to bring taxpayers with undisclosed foreign income, accounts, and assets into compliance for U.S. income tax purposes. Taxpayers who were eligible to participate in OVDP and made timely voluntary disclosures were provided the opportunity to receive protection from criminal liability and to resolve their civil tax and penalty obligations on a standardized penalty framework.

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