Offshore Accounts: The Beat Goes On

July 16, 2015  |  New York Law Journal

In its seventh year and fourth iteration, the Offshore Voluntary Disclosure Program (“OVDP”) remains the best opportunity for taxpayers who intentionally evaded their tax and reporting obligations to bring themselves into compliance and avoid criminal prosecution. However, not every current or former offshore accountholder who failed to comply with those obligations acted with a culpable state of mind, and the IRS has come to recognize the inequity of treating taxpayers who made good faith mistakes as harshly as those who acted willfully. In this article, I discuss the various options available to taxpayers with previously undisclosed offshore accounts.

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