News & Insights

IRS Offshore Voluntary Disclosure Program Coming to an End

By John Gatti and Cody Attisha
March 16, 2018

On March 13, 2018, the IRS announced that it is ending the 2014 Offshore Voluntary Disclosure Program (OVDP) on September 28, 2018.   IRS Commissioner David Kautter stated that “Taxpayers have had several years to come into compliance with U.S. tax laws under this program… All along, we have been clear that we would close the program at the appropriate time, and we have reached that point. Those who still wish to come forward have time to do so.”

Since 2009, more than 56,000 taxpayers came clean through OVDP.   Although the OVDP is coming to end, Don Fort, Chief, IRS Criminal Investigation has made it clear that the IRS “remains actively engaged in ferreting out the identities of those with undisclosed foreign accounts with the use of information resources and increased data analytics… and “stopping offshore tax noncompliance remains a top priority of the IRS.”

Despite OVDP ending, taxpayers who were unaware of their foreign bank account reporting obligations may still be eligible for Streamlined Filing Compliance Procedures. 

To discuss your foreign reporting obligations or for further information about this Alert, please contact John Gatti or Cody Attisha.  


John D. Gatti has more than 20 years of experience in business law and the laws of taxation. A Certified Public Accountant as well as an attorney, John concentrates his practice in the areas of taxation, mergers and acquisitions, business law, real estate law, and estate planning. He chairs the firm’s Taxation Practice Group.

John regularly advises clients in a variety of areas including mergers and acquisitions, business formations, succession planning, real estate, joint ventures and general corporate matters.

He has extensive experience involving a variety of federal, state and multi-state income and franchise tax issues relating to corporate, partnership and limited liability company acquisitions, dispositions and restructurings. John advises on a wide range of tax issues including Subchapters C, K and S, consolidated returns, income tax accounting and captive insurance companies.

Prior to joining the firm, John served at a nationally recognized accounting firm specializing in the tax aspects of mergers and acquisitions, and provided tax advice to clients in various industries including the automotive, transportation, publishing, food manufacturing and health care segments. Email John.

Cody Attisha's practice focuses on taxation law, corporate law, and mergers and acquisitions. 

Prior to joining Kerr Russell, Cody served as a tax associate with an international “Big 4” accounting firm where he advised on various aspects of federal, state and local taxation. Cody assisted with tax advisory relating to corporate restructurings and mergers and acquisitions. He was also involved with credits and incentives such as working with local community development entities in applying for new market tax credit allocations. Cody also has significant tax controversy experience including petitioning the Michigan Tax Tribunal and assisting with defending clients before the IRS and State of Michigan. Previously, Cody worked as a tax associate for a boutique tax controversy law firm in Southfield, Michigan. Email Cody.


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