Tag Archives: OVDP 2012

IRS reopens the Offshore Voluntary Disclosure Program and promises new procedures for U.S. citizens living outside the United States

So said the Big Bad Wolf

I can’t believe it. On January 5, 2012 I wrote a post about OVDI called: The Taxpayer, the IRS and the Cross Border professionals – where to go from here. Six hours ago I finished a lengthy post about OVDI called: Taxpayer Advocate vs. The IRS – It’s a question of trust.  I thought I would enter: “OVDI Blog Post Retirement”. My point was that the IRS has a real trust issue. |The “cross-border professionals are not much help either. And then, almost on cue (while I was writing the post) the IRS is at again! To emulate a famous Ronald Reagan quote:

“There he goes again!”

Can you believe it? The IRS has extended OVDI. I think it was Einstein who said that the height of insanity is to continue to repeat the same thing that doesn’t work. Many people don’t understand how they are perceived by others. I would say that Commissioner Shulman qualifies. He doesn’t  get it.  OVDI has irreparably damaged the trust that the practitioners and the taxpayers have in the IRS. No matter what Mr. Shulman chooses to believe, the IRS cannot function without trust. He is seriously out of touch with reality. OVDI has made people more reluctant to come forward to clean up their problems. Why? Because there is no clear direction from the IRS. All Mr. Shulman seems to be able to say is: come on in to the see the IRS and we will take your life savings. He must be kidding. The rules for OVDI 2011 were long and comprehensive. Very few people understood them completely. But in a nutshell here was the OVDI 2011 offer:

“If you file 8 years of returns, spending a large part of your life doing this and thousands (in many cases tens of thousands of dollars to do this) you will agree to give us 25% of your net worth. Why you ask? Because if you have a foreign bank and/or you live outside the United States you are a criminal – nothing but a common criminal.” Continue reading