Is the Offshore Voluntary Disclosure Initiative (OVDI) still in full swing?
Yes. Like its predecessors, the 2009 OVDP, which ran from March 23, 2009 through October 15, 2009, and the 2011 OVDI, which ran from February 8, 2011 through September 9, 2011, the 2012 OVDI addresses the civil side of a taxpayer’s voluntary disclosure of foreign accounts and assets by defining the number of tax years covered and setting the civil penalties that will apply. This is a form of amnesty from the IRS.
Unlike the 2009 OVDP and the 2011 OVDI, there is not a set deadline for taxpayers to apply. However, the terms of this program could change at any time going forward. For example, the IRS may increase penalties or limit eligibility in the program for all or some taxpayers or defined classes of taxpayers – or decide to end the program entirely at any point.
Certainly more discussion is always required for those faced with this situation. Brace yourself.