The program was initiated in 2009 and allows U.S. taxpayers who previously did not report the offshore income and assets to voluntarily resolve the past non-compliance in exchange for a protection from criminal liability and a limit on civil penalty exposure.
According to the IRS, “while the program has been successful in the past, there has been a significant decline in the number of taxpayers participating as well as an increase in awareness of offshore tax and reporting obligations.”
IRS will continue offering the following disclosure options:
- IRS-Criminal Investigation Voluntary Disclosure Program;
- Streamlined Filing Compliance Procedures;
- Delinquent FBAR submission procedures; and
- Delinquent international information return submission procedures.