The Offshore Voluntary Disclosure Program (OVDP) was specifically designed to provide U.S. taxpayers protection from criminal liability due to willful failure to report foreign financial assets and also the conditions for satisfying the civil tax and penalty liabilities with respect to those assets. It can be expected that incremental information will become available to the IRS under FATCA and Foreign Financial Asset Reporting [IRC §6038D] yielding greater influence towards taxpayer compliance.

1. IRS Newswire Oct. 21, 2016
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Issue Number: IR-2016-137
Inside This Issue
Offshore Voluntary Compliance Efforts Top
$10 Billion;
More Than 100,000Taxpayers Come Back into
Compliance
IR-2016-137, Oct. 21, 2016
WASHINGTON — As international compliance efforts
pass several new milestones, the Internal Revenue
Service reminds U.S. taxpayers with undisclosed offshore
accounts that they should use existing paths to come into
full compliance with their federal tax obligations.
Updated data shows 55,800 taxpayers have come into the
Offshore Voluntary Disclosure Program (OVDP) to resolve
their tax obligations, paying more than $9.9 billion in
taxes, interest and penalties since 2009. In addition,
another 48,000 taxpayers have made use of separate
streamlined procedures to correct prior non-willful
omissions and meet their federal tax obligations, paying
approximately $450 million in taxes, interest and
penalties.
“The IRS has passed several major milestones in our
offshore efforts, collecting a combined $10 billion with
100,000 taxpayers coming back into compliance,” said
IRS Commissioner John Koskinen. “As we continue to
receive more information on foreign accounts, people’s
ability to avoid detection becomes harder and harder. The
IRS continues to urge those people with international tax
issues to come forward to meet their tax obligations.”
Under the Foreign Account Tax Compliance Act (FATCA)
and the network of inter-governmental agreements (IGAs)
between the U.S. and partner jurisdictions, automatic

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third-party account reporting has entered its second year.
More information also continues to come to the IRS as a
result of the Department of Justice’s Swiss Bank Program.
As part of a series on non-prosecution agreements, the
participating banks continue to provide information on
potential non-compliance by U.S. taxpayers.
OVDP offers taxpayers with undisclosed income from
foreign financial accounts and assets an opportunity to get
current with their tax returns and information reporting
obligations. The program encourages taxpayers to
voluntarily disclose foreign financial accounts and assets
now rather than risk detection by the IRS at a later date
and face more severe penalties and possible criminal
prosecution.
The IRS developed the Streamlined Filing Compliance
Procedures to accommodate taxpayers with non-willful
compliance issues. Submissions have been made by
taxpayers residing in the U.S. and from those residing in
countries around the globe. The streamlined procedures
have resulted in the submission of more than 96,000
delinquent and amended income tax returns from the
48,000 taxpayers using these procedures. A separate
process exists for those taxpayers who have paid their
income taxes but omitted certain other information returns,
such as the Report of Foreign Bank and Financial
Accounts (FBAR).
Form Updates and Change in Phone Numbers
The IRS recently revised the certification forms used for
the Streamlined Filing Compliance Procedures. The most
current versions of Forms 14653 and 14654 are available
on IRS.gov.
Commonly used telephone numbers relating to the Offshore
Voluntary Disclosure Program (OVDP) and the Streamlined
Filing Compliance Procedures have also changed.
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