Robert E. McKenzie addresses IRS reversal of Offshore Voluntary Disclosure Program in The Wall Street Journal and Accounting Today
Arnstein & Lehr Chicago Partner Robert E. McKenzie offered his thoughts in a March 8 Accounting Today article on the Internal Revenue Service notifying tax attorneys around the country that their clients have been disqualified from participation in the Offshore Voluntary Disclosure Program (OVDP), even after they had initially been accepted in the program. The Wall Street Journal also asked Mr. McKenzie for his thoughts on the subject.
The IRS offered the OVDP as a way to encourage taxpayers with previously undisclosed bank accounts, particularly at Swiss banks like UBS, to come forward voluntarily, pay their back taxes and avoid heavy penalties. In some cases, the clients and their tax practitioners had filed amended returns and paid the back taxes and interest on previously undisclosed accounts at foreign banks after receiving assurances that they had been accepted in the program. Now some are concerned that they will face stiff penalties and even the possibility of prison sentences after coming forward voluntarily.