The Internal Revenue Service announced yesterday that it will end the Offshore Voluntary Disclosure Program (“OVDP”) on September 28, 2018 and wind it down over the coming months. IR-2018-52. The IRS established the OVDP voluntary compliance program in 2009, with its current incarnation set up in 2014, to allow taxpayers who willfully failed to report foreign bank accounts/assets to come forward voluntarily without fear of criminal liability, and to limit their civil penalties on specified terms.
On May 10, 2017, Attorney General Sessions issued a Memorandum titled Department Charging and Sentencing Policy. Prosecutors were instructed to “charge and pursue the most serious, readily provable offense” and “disclose to the sentencing court all facts that impact the sentencing guidelines or mandatory minimum sentences.”