Court Rejects Challenge to OVDP Transition Rules

Overview


Andrew Roberson and Emily Mussio wrote this bylined article on two IRS programs to comply with US rules for disclosure of offshore income. A federal court recently prohibited switching between the Offshore Voluntary Disclosure Program (OVDP) and the Streamlined Filing Compliance Procedures (SFCP), the authors wrote, so “taxpayers who have failed to comply with their US tax filing and information reporting obligations should … seek appropriate advice regarding whether, and which, disclosure program to pursue.”