Scott Michel Comments on Closure of IRS Offshore Voluntary Disclosure Program

03.23.2018
MLex US Tax Watch

The Internal Revenue Service announced March 13 that it will be ending the 2014 Offshore Voluntary Disclosure Program (OVDP) on Sept. 28.

. . .

While the winding down of the OVDP didn't come as a total surprise, there is some concern about what shape a post-Sept. 28 voluntary disclosure process will take. Scott D. Michel of Caplin & Drysdale noted that the traditional CI Voluntary Disclosure Practice has been in place for many years (dating back to the early 1950s), but he said the IRS has provided very little guidance on it.

Section 9.5.11.9 of the Internal Revenue Manual describes what constitutes a timely disclosure and lays out several methods for providing disclosures, but those rules aren't comprehensive or clear-cut, Michel said.

However, the IRS's request for suggestions on future Voluntary Disclosure Practice procedures is an encouraging sign, he said. "This is an opportunity for the tax bar that practices in this area to really put its heads together and suggest a uniform, efficient and easy-to-understand voluntary disclosure procedure that practitioners can rely on in the future," said Michel.

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Excerpt taken from the article “IRS winding down Offshore Voluntary Disclosure Program” by Kristen Parillo for MLex.

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