The recent release of the OVDP Streamlined Domestic Offshore Procedures (with a deadline of August 4th) was greeted with excitement in many quarters. Who wouldn’t want to reduce penalties from 27.5% down to 5% for inaccurate FBAR and foreign account reporting to the IRS? The short answer: those who for whom it is entirely possible that the IRS will find their conduct to be “willful” in an attempt to under-report offshore assets and income in an attempt to avoid paying US taxes. There are several options available to US taxpayers and expatriates under the OVDP program, and relief from criminal and civil liability is the reason to submit an OVDP application. The IRS has made it clear that it intends to carefully scrutinize each case to make their own determination upon “willful” or “non-willful” conduct, and those that file under the streamlined guidelines without serious consideration continue to risk criminal and civil liabilities. Contact experienced tax attorney Janathan Allen to discuss your unique circumstances, and take advantage of the extensive protection of attorney-client privilege.


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