On November 20, 2018, the IRS issued a Memorandum, describing the process for all voluntary disclosures following the closing of the 2014 OVDP on September 28, 2018. The new procedures are effective for all disclosures after September 28, 2018. Under the new procedures, the taxpayers with hidden foreign bank accounts, whose behavior may be considered willful, will find stricter requirements and higher penalties.
Holtz, Slavett & Drabkin is proud to sponsor the 35th National Institute on Criminal Tax Fraud and Eighth Annual National Institute on Tax Controversy, which will take place on December 13-15, 2018, at the Wynn Hotel in Las Vegas, Nevada.
In general, the United States has five years to start criminal proceedings in a criminal case (either through an indictment or information). 18 U.S.C. § 3282. However, there are several statutes that could suspend or extend this five-year period, and an individual might not even know if the statute of limitations has been extended.
IRS Offshore Voluntary Disclosure Program to End Soon
