IRS Offshore Voluntary Disclosure Program to end on September 28

August 31, 2018

The United States Internal Revenue Service ("IRS") published IR-2018-52 earlier this year announcing that the Offshore Voluntary Disclosure Program ("OVDP") would be closing on September 28, 2018. The IRS now warns that the deadline is less than a month away.

The OVPD is a voluntary program designed to incentivize taxpayers with exposure to potential criminal liability and/or substantial civil penalties due to willful failure to report and pay applicable taxes on foreign financial assets to disclose such information by granting them: (1) protection from criminal liability and (2) favorable terms for resolving their civil tax and penalty obligations.

Other IRS program options for addressing failure to comply with U.S. tax laws for expats, U.S. citizens and U.S. residents with foreign financial assets will continue into the foreseeable future, including: (1) Streamlined Filing Compliance Procedures ("Streamlined Program"), (2) Delinquent FBAR submission procedures, and (3) Delinquent international information return submission procedures. However, these programs are not as lenient as the OVDP. For example, the Streamlined Program does not immunize taxpayers from being referred to a criminal investigation like the OVDP currently does. Further guidance on offshore asset disclosure and compliance is available in the IRS website.

Goldman Antonetti & Córdova, LLC stands ready to assist as you and your business adjust to Puerto Rico's regulatory and legal changes. If you need further assistance in this area, please contact the following members of our firm:

Fernando Bruno Ramírez de Arellano, Esq.
787-759-4125
[email protected]

Rebecca Cuevas Fontán, Esq., CPA
787.759.4153
[email protected]

Roberto Montalvo Carbia, Esq.
787.759.4123
[email protected]

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