Tag Archives: Publication 54

Why IRS conduct may contribute to establishing “Reasonable Cause” for failure to file Mr. FBAR

Two solitudes – To “OVDP” or to NOT “OVDP”



When it comes to the “compliance dilemma”, the thinking seems to be:

“To OVDP or to NOT OVDP” – Note the Isaac Brock press release on OVDP 2012

That question has consumed created enormous “life altering anxiety” and a large number of LCUs life credit units). Readers of this blog will have seen a number of compliance options acknowledged and considered. These range from “compliance going forward” at one end of the spectrum to OVDP at the other. At a minimum it is important to consider the ramifications of all options. That said, there are a large number of lawyers who believe that entering OVDP is the “default option”. At least one lawyer as stated his view that compliance means OVDP. (The validity of this position was strongly questioned here. At least one other lawyer has stated that he has “always gone in under reasonable cause”.

In any event, I have come to see that the question is NOT:

“To OVDP or to NOT OVDP”.

The question is:

“To reasonable cause or to NOT reasonable cause” Continue reading