Since 2009, the IRS has had various programs for taxpayers that failed to report offshore financial accounts and other assets, including interests in foreign trusts and foreign corporations  The current program began in 2014, and on March 13, 2018, the IRS has announced that effective September 28, 2018, taxpayers will no longer be able to take advantage of the Offshore Voluntary Disclosure Program (“OVDP”).  All taxpayers that have been contemplating submitting a voluntary disclosure under OVDP should do so quickly.  After September 28, 2018, the IRS will no longer accept submissions.  

 It is speculated that the IRS now has sufficient information to identify non-compliant taxpayers on its own and that the benefit of granting any type of amnesty or pre-determined penalty is no longer a value proposition to the IRS.  Taxpayers will continue to be able to take advantage of the Streamlined Filing Procedures, but that is only applicable to taxpayers who had no knowledge of their filing requirement.  It becomes more difficult every day to argue that a taxpayer had no knowledge of the foreign account filing requirement since this issue has been continuously published by the IRS and the private sector – accountants and attorneys.