From 2009 until 2014, the IRS offered an annual program formally known as the “Offshore Voluntary Disclosure Program.” According to the IRS, the program was “specifically designed for taxpayers with exposure to potential criminal liability and/or substantial civil penalties due to a willful failure to report foreign financial assets and pay all tax due in respect of those assets.”
However, a lack of taxpayer participation and general increase in awareness of tax compliance obligations led to the program’s aforementioned closure in 2014. Today, taxpayers seeking an avenue through which to disclose offshore noncompliance should refer to the IRS Criminal Investigation Voluntary Disclosure Practice.