Is it Possible to Obtain a Refund of the OVDP Offshore Penalty
By Anthony Diosdi Since the Internal Revenue Service (“IRS”) has launched the initial Offshore Voluntary Disclosure Program (“OVDP”) in 2009, more than 56,000 people have disclosed their foreign financial accounts to the IRS. At last count, the IRS has collected over $10 billion dollars in tax, interest, and penalties from various targeted offshore voluntary disclosure programs.The OVDP is a subset of the IRS Criminal Investigation Division’s longstanding Voluntary Disclosure Practice. The Voluntary Disclosure Practice is a longstanding practice of IRS Criminal Investigation (“CI”) whereby CI takes timely, accurate, and complete voluntary disclosures into account in deciding whether to recommend to the Department of Justice that a taxpayer be criminally prosecuted. It enables noncompliant taxpayers to resolve their tax liabilities and minimize their chance of criminal prosecution. When a taxpayer truthfully,…