I am very concerned about the future of the Offshore Voluntary Disclosure Program or OVDP. This program provides an option for US citizens, US expatriates and foreign nationals living and working in the United States to disclose previously hidden or mistakenly unreported foreign accounts and assets. The purpose of this “application” is to request acceptance into the program, and in return the IRS agrees to release the taxpayer from potential criminal exposure. For the next month (until June 30) our clients are in a position to consider OVDP, and to apply if it is the right alternative based upon their unique circumstances. After July 1, the IRS will have access to most foreign account and asset information, and will no longer need the cooperation of the public. It is very possible that the IRS will close the window on the OVDP, and begin pursuing those who have not taken action to update their FBARs and apply through OVDP to avoid the extreme penalties and interest which will apply.
