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Category: International Tax Blog

2015 OVDP: Where We Stand

The 2015 OVDP Playbook The 2015 OVDP is essentially the same game but the goalposts have been moved in a big way. FATCA (The Foreign Account Tax Compliance Act) came into effect last July and has been gradually building ahead of steam as it is implemented around the world. Interested in finding out more about… Read more »


U.S. Taxpayers Living Abroad: the 2014 Streamlined Foreign Offshore Procedures For taxpayers living outside the United States, the 2014 OVDP rules bring significant changes to the streamlined program that was available under the 2012 program.  Under the 2014 OVDP Streamlined Foreign Offshore Procedures, like the 2012 streamlined OVDP program, all offshore penalties will be waived… Read more »


2014 STREAMLINED OVDP (OVDI) VOLUNTARY DISCLOSURE OPTION Under the 2012 OVDP programs, and prior OVDI programs, there was a streamlined procedure that allowed for a complete waiver of all offshore penalties, but was only available to non-residents who meet certain conditions.  This prior Streamlined OVDP program was replaced with the 2014 Streamlined Filing Compliance Procedures. … Read more »


IRS ANNOUNCES 2014 OVDP (OVDI): MAJOR CHANGES TO THE OFFSHORE VOLUNTARY DISCLOSURE PROGRAM One June 3rd, 2014, IRS commissioner John Koskinen acknowledged the substantial burdens faced by non-willful violators and announced that significant changes were imminent. Within weeks following the announcement, on June 18th, 2014, the IRS announced the release of the 2014 OVDP / OVDI… Read more »

Where Did All the Quiet Disclosures Go?

With Quiet Disclosures Under Fire, Consider Opting-Out of OVDI/OVDP (Qualified Quiet Disclosure)? In the past, the IRS has been lenient with taxpayers that file FBARs and other tax returns past the due dates through quiet disclosures, or essentially not using the voluntary disclosure program (OVDI/OVDP) to become compliant. Often, these taxpayers believed that their circumstances… Read more »

Streamlined OVDP for Canadians

AMERICANS IN CANADA: CAN YOU QUALIFY FOR THE STREAMLINED OVDP? The New Streamlined Offshore Voluntary Disclosure Program In an action that many interpret as (partial) recognition of the complexity of the Internal Revenue Code, the Internal Revenue Service (IRS) has created the streamlined OVDP to give low compliance risk taxpayers that are resident outside of… Read more »

All About OVDI (OVDP): the IRS’s Offshore Voluntary Disclosure Program

OVDI: Tax Amnesty Within the IRS For Americans with more than $10,000 in one or more undisclosed foreign bank accounts, entering the IRS OVDI (OVDP) program may be the best way to come into compliance, and avoid the possibility of criminal tax fraud charges, while minimizing exposure to penalties.  Otherwise, taxpayers caught with these undisclosed foreign accounts will… Read more »