Side-by-side Comparison of 2012 and 2014 IRS OVDP FAQ

By Alexey Manasuev

On June 18, 2014, the IRS released significant changes to its Offshore Voluntary Disclosure Program (“OVDP”) and enhancements to the Streamlined Filing Compliance Procedures (“SFCP”).

We thought it would be useful to have a side-by-side comparison of Frequently Asked Questions (FAQ) under the 2012 IRS Offshore Voluntary Disclosure Program (“OVDP”) and the recently announced (on June 18, 2014) 2014 FAQ under the IRS OVDP. The purpose of the table is to serve as a practical tool for tax practitioners who evaluate the changes to the OVDP announced by the IRS in evaluating procedural alternatives available to taxpayers in resolving their U.S. tax compliance issues. The table will be of particular interest to those taxpayers and tax advisors who currently participate in the 2012 OVDP or whose facts and circumstances may warrant a more favorable penalty structure under the SFCP. Although the value of the side-by-side comparison is now limited because of the passed June 30, 2014 deadline for applying for the transitional treatment, the side-by-side comparison may still be of use to some practitioners and U.S. taxpayers who want to have a quick and easy reference material identifying the changes to the programs. You can review and download the complete side-by-side comparison table here.