The IRS began an open-ended offshore voluntary disclosure program (OVDP) in January 2012 on the heels of strong interest in the 2011 and 2009 programs. The IRS may end the 2012 program at any time in the future. The IRS is offering people with undisclosed income from offshore accounts another opportunity to get current with their tax returns. The 2012 OVDP has a higher penalty rate than the previous program but offers clear benefits to encourage taxpayers to disclose foreign accounts now rather than risk detection by the IRS and possible criminal prosecution.
The Voluntary Disclosure Practice is a longstanding practice of IRS Criminal Investigation (CI) whereby CI takes timely, accurate, and complete voluntary disclosures into account in deciding whether to recommend to the Department of Justice that a taxpayer be criminally prosecuted. It enables non-compliant taxpayers to resolve their tax liabilities and minimize their chance of criminal prosecution. When a taxpayer truthfully, timely, and completely complies with all provisions of the voluntary disclosure practice, the IRS will not recommend criminal prosecution to the Department of Justice.
Taxpayers with undisclosed foreign accounts or entities should make a voluntary disclosure as it enables them to become compliant, avoid substantial civil penalties and generally eliminate the risk of criminal prosecution. Making a voluntary disclosure also provides the opportunity to calculate, with a reasonable degree of certainty, the total cost of resolving all offshore tax issues. Taxpayers who do not submit a voluntary disclosure run the risk of detection by the IRS and the imposition of substantial penalties, including the fraud penalty and foreign information return penalties, and an increased risk of criminal prosecution.
The application for an Offshore Voluntary Disclosure Program is a highly complex and extensive process which requires thorough preparation and professional help. Our tax attorneys have extensive experience in representing clients during the Offshore Voluntary Disclosure Program application process and are able to assist clients with the most complicated situations. Please contact the Law Offices of Daria S Brovchenko to speak with a tax attorney.
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The Law Offices of Daria S. Brovchenko are located in San Diego, CA. We represent clients throughout Southern California including, San Diego, Los Angeles, Poway, Vista, Chula Vista, El Cajon, Coronado, La Jolla, Pacific Beach, Oceanside, Carlsbad, Encinitas, Escondido, Rancho Bernardo, Del Mar, Solana Beach, Scripps Ranch, La Mesa, Lakeside, Eastlake, Bonita, Anaheim, Santa Ana, Newport Beach, San Diego County, Orange County and Riverside County. We also represent clients globally, including Russia, China, Italy, Japan, Brazil and Mexico.