Less than two months are left before the 2014 IRS Offshore Voluntary Disclosure Program (“2014 OVDP”) closes on September 28, 2018. 2014 OVDP may offer great benefits to taxpayers with undisclosed foreign accounts, such as the possibility of avoiding criminal penalties and greatly reducing FBAR civil penalties. Yet, entering 2014 OVDP also implies a great variety of obligations and complications that many taxpayers will find overly invasive and burdensome. Moreover, non-willful taxpayers may resent not only the amount of paperwork, but also the 27.5% to 50% OVDP Miscellaneous Offshore Penalty.
Furthermore, 2014 OVDP has its own eligibility requirements which may simply prevent a taxpayer from being able to participate in the program. Unfortunately, the taxpayer may only find out about it after he submits his OVDP application, thereby exposing himself to potential IRS investigation and penalties.
In sum, entering 2014 OVDP is an important and highly complex decision that requires a detailed evaluation of the taxpayers’ facts. 2014 OVDP is not the best solution for everyone, but it may be a critical opportunity to settle past tax noncompliance for some taxpayers (especially taxpayers whose noncompliance is likely to be considered “willful” by the IRS) – an opportunity that should not be wasted.
Such legal analysis should only be done by a skilled international tax attorney who specializes in the area of offshore voluntary disclosures. The stakes are simply too high to entrust a matter of such importance to anyone else.
Experienced International Tax Attorney Sherayzen Can Help You With Your Offshore Voluntary Disclosure
Mr. Eugene Sherayzen is an international tax attorney who specializes in offshore voluntary disclosures. In fact, this speciality occupies more than 80% of his entire practice. Mr. Sherayzen has helped his clients with respect to every major IRS voluntary disclosure program, including 2009 OVDP, 2011 OVDI, 2012 OVDP, 2014 OVDP, Streamlined Domestic Offshore Procedures, Streamlined Foreign Offshore Procedures, Delinquent FBAR Submission Procedures and Delinquent International Information Return Submission Procedures.
Additionally, Mr. Sherayzen has conducted a great number of statutory voluntary disclosures based on Reasonable Cause exception or so called “Noisy Disclosures” (they were very popular prior to 2009 as well as between 2009 OVDP and the creation of the Streamlined Filing Compliance Procedures).
Furthermore, Mr. Sherayzen represented his clients during the IRS audits of offshore voluntary disclosures, has extensive experience with IRS appeals and federal court litigation.
Contact Attorney Sherayzen Before Entering 2014 OVDP
Such an extensive work with offshore voluntary disclosures makes Mr. Sherayzen one of the most experienced offshore voluntary disclosure lawyers whose opinion should be obtained before entering 2014 OVDP.