Changes to the IRS Disclosure Programs

Yesterday, IRS Commissioner Koskinen’s News Release included the following statement- http://www.irs.gov/uac/Newsroom/Statement-of-IRS-Commissioner-John-Koskinen

The key points to note are –

1. Streamlined appears to have been split in 2. Non-resident and Resident. 
• The Nonresident program — referred to as Streamlined Foreign Offshore Procedures — is described on a web page titled: U.S. Taxpayers Residing Outside the United States – http://www.irs.gov/Individuals/International-Taxpayers/U-S-Taxpayers-Residing-Outside-the-United-States
• The Resident program — referred to as Streamlined Domestic Offshore Procedures — is described on a web page titled U.S. Taxpayers Residing in the United States – http://www.irs.gov/Individuals/International-Taxpayers/U-S-Taxpayers-Residing-in-the-United-States
2. Delinquent FBARs have a separate procedure here – http://www.irs.gov/Individuals/International-Taxpayers/Delinquent-FBAR-Submission-Procedures
3. Delinquent International Information Return Submission Procedures are new. This would include forms 5471, 8865 (foreign corporations, foreign partnerships) etc. Note the need for a statement of all facts establishing reasonable cause for the failure to file. Details are here- http://www.irs.gov/Individuals/International-Taxpayers/Delinquent-International-Information-Return-Submission-Procedures
4. Finally there is the new OVDP 2014 with new FAQs. Note paragraph 1.1 on the changes from the original OVDP 2012. http://www.irs.gov/Individuals/International-Taxpayers/Offshore-Voluntary-Disclosure-Program-Frequently-Asked-Questions-and-Answers-2012-Revised

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