The new revisions to the US offshore voluntary disclosure initiative, which we posted on 6/18/14 "IRS Makes Changes to Offshore Programs; Revisions Ease Burden and Help More Taxpayers Come into Compliance", now provides for the followingTransition rules:- Purpose of transitional treatment. Transitional treatment under OVDP will allow taxpayers "currently participating" (see below) in OVDP who meet the eligibility requirements for the expanded Streamlined Filing Compliance Procedures announced on June 18, 2014, an opportunity to remain in the OVDP while taking advantage of the favorable penalty structure of the expanded streamlined procedures. (FAQ #1)
- "Currently participating." A taxpayer is considered to be currently participating in an OVDP for purposes of receiving transitional treatment if: (i) before July 1, 2014, he has mailed to IRS Criminal Investigation his OVDP voluntary disclosure letter and required attachments; and (ii) as of July 1, 2014, he has either: (a) remained in OVDP but not yet completed the OVDP certification process where a Form 906 Closing Agreement has been fully executed by IRS; or (ii) opted out of OVDP, but not yet received a letter initiating an examination and enclosing a Notice 609. (FAQ #2) A taxpayer will not be considered to be currently participating in OVDP for purposes of receiving transitional treatment unless, as of July 1, 2014, he has mailed to IRS Criminal Investigation his voluntary disclosure letter and required attachments. (FAQ #3) A taxpayer whose case has been removed from OVDP by IRS is not eligible for transitional treatment. (FAQ #4)
- Seeking transitional treatment. A taxpayer is not required to opt out of the OVDP to receive transitional treatment, but must provide certain specified information to IRS in the manner stated. (FAQ #6) Transition treatment is not automatic, and IRS must agree that the taxpayer is eligible for it and that the available information is consistent with the taxpayer's certification of non-willful conduct. (FAQ #7) There are no appeal rights within OVDP, including the determination of whether the taxpayer qualifies for transitional treatment. (FAQ #8)
Do You Have Unreported Foreign Income?
Do Want Your Current OVDP To Transition To The Revised Streamlined Filing Compliance Procedures?
Contact the Tax Lawyers at
Marini & Associates, P.A.
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