U.S. citizens abroad who are noncompliant with their tax obligations but aren’t willfully evading taxes may be able to come into compliance under a new program to be announced by the Internal Revenue Service.
According to prepared Remarks of John A. Koskinen Commissioner Internal Revenue Service Before The U.S. Council For International Business-OECD International Tax Conference on Washington, D.C. June 3, 2014:
“Now, while the 2012 OVDP and its predecessors have operated successfully, we are currently considering making further program modifications to accomplish even more.
We are considering whether our voluntary programs have been too focused on those willfully evading their tax obligations and are not accommodating enough to others who don’t necessarily need protection from criminal prosecution because their compliance failures have been of the non-willful variety. For example, we are well aware that there are many U.S. citizens who have resided abroad for many years, perhaps even the vast majority of their lives. We have been considering whether these individuals should have an opportunity to come into compliance that doesn’t involve the type of penalties that are appropriate for U.S.-resident taxpayers who were willfully hiding their investments overseas.
We are also aware that there may be U.S.-resident taxpayers with unreported offshore accounts whose prior non-compliance clearly did not constitute willful tax evasion but who, to date, have not had a clear way of coming into compliance that doesn’t involve the threat of substantial penalties.”
“We expect we will have much more to say on these program enhancements in the very near future. So stay tuned.”
Taxpayers Who Wish To Take Advantage Of These New Compliance Procedures Must Act Quickly!
Original Post By: Ronald Marini