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By Benjamin Tolub, Esq.(1)
The Internal Revenue Service (“IRS”) announced, on June 18, 2014, major changes to its current offshore voluntary disclosure programs. The programs affected are the 2012 Streamlined Filing Compliance Procedures for Non-Resident, Non-Filer U.S. Taxpayers (the “Streamlined Procedures”) and the 2012 Offshore Voluntary Disclosure Program (“OVDP”).
In general, the changes to the programs soften the rules for non-willful filers and, at the same time, potentially increase penalties for willful non-compliance. The changes to the OVDP provide that (i) additional information will be required from taxpayers applying to the program, (ii) the existing reduced penalty percentage for non-willful taxpayers will be eliminated, (iii)...
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