Celesq® Upcoming Webcasts

Date Published: 07/18/2019

The Future of IRS Voluntary Disclosures in a Post-OVDP World

Following the termination last fall of its immensely successful Offshore Voluntary Disclosure Program (OVDP), the Internal Revenue Service (IRS) has announced a new regime to govern all voluntary disclosures regarding tax noncompliance. These new procedures apply to both domestic and offshore voluntary disclosures, and in many ways they replicate the procedures under the now-shuttered OVDP. In other ways, the new procedures are significantly different, particularly the new civil penalty framework, which calls for the imposition of a 50 percent penalty on undisclosed offshore financial assets, and a 75 percent civil fraud penalty on unpaid taxes. This program will trace the history of IRS voluntary disclosure programs, review key elements of the new regime announced in November 2018, and provide guidance to practitioners considering whether voluntary disclosures are warranted.

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