Caroline D. Ciraolo moderated the panel titled "OVDP – End Of An Era" at the ABA Section of Taxation 2018 Fall Tax Meeting

Though its use by taxpayers has substantially dwindled in recent years, for nearly a decade, the Offshore Voluntary Disclosure Program was a major component of the IRS’s effort to bring US taxpayers into compliance with their offshore reporting obligations, and helped facilitate the return of billions of dollars to the tax base. 

Neither the IRS nor Department of Justice have given any indication that they have stopped searching for offshore tax cheats and no doubt there are many individuals who still need to come in from the cold. But, without the OVDP, what advice can the practitioner provide? A panel of experienced lawyers and IRS officials discussed this question and shared their thoughts on how and whether a taxpayer can still disclose previously unreported offshore assets without serious risk of criminal prosecution or huge offshore penalties.