As originally highlighted in our March 2018 newsletter the Offshore Voluntary Disclosure Program (OVDP) will be closing effective September 28, 2018. All OVDP submissions must be postmarked on or before this date to qualify for the program. This IRS article Closing the 2014 Offshore Voluntary Disclosure Program Frequently Asked Questions and Answers provides an excellent review of the closure and highlights the decline in the number of taxpayers taking advantage of the program.

Most notably however, the streamlined program remains open to those taxpayers with undeclared foreign assets resulting from “non-willful conduct.” The IRS defines non-willful conduct as “conduct that is due to negligence, inadvertence, mistake, or conduct that is the result of a good faith misunderstanding of the requirements of the law.”

The streamlined program has been very useful in the mobility industry for individuals moving to the US who discover, once they attain US tax residency status, that they have reporting requirements they were not aware of. This has also been the case for many foreign nationals who have US reporting requirements due to their attainment of US citizenship through parentage or from being born in the US (even though they may never have lived in the US.) The IRS provides excellent information on streamlined filing compliance procedures here.

Should you have questions regarding the disclosure of foreign assets for US tax residents, please contact us at or +1.888.486.2695, or visit our Mobility Tax Services page to see what assistance we can provide.

The information provided above is for general guidance only and should not be utilized in lieu of obtaining professional tax and/or legal advice.