IRS “Reopened” Offshore Voluntary Disclosure Program: 2012-?
In January, the IRS announced it reopened indefinitely its offshore voluntary disclosure program.
It’s no surprise. After all, the IRS has collected more than $4.4 billion from the previous two programs than ran in 2009 and 2011.
Yes, that’s billion, as in $4,400,000,000.
While there’s a comprehensive FAQ regarding the 2011 program, I could not locate any information for the current program other than the press release linked above. Strange, I thought, considering the release said more details would be released “within the next month.” And that was in January.
So I called the offshore voluntary disclosure hotline, and left a message. Apparently, they never pick up. But that’s okay, because an IRS representative returned my message within one hour. Impressive.
He said the IRS hasn’t gotten around to posting the current program’s details yet. Great. He added, however, that the 2011 OVDI program parameters are the same as the current program, except the general miscellaneous offshore penalty is now 27.5% instead of 25%, and that the lookback period will change from 2003 through 2010 to 2004 through 2011.
Although I was pleased to receive an answer, I’m left unsatisfied. I would much rather have published IRS guidance to rely on when counseling clients than oral IRS guidance.
And in this case, it’s especially so because the terms of the program could change at any time.
That’s the lovely IRS for you. After a while, you just begin to expect these administrative inadequacies.