(New) IRS Post OVDP Compliance Campaign to Enforce Reporting (Board Certified Tax Specialist)

(New) IRS Post OVDP Compliance Campaign to Enforce Reporting (Board Certified Tax Specialist)

(New) IRS Post OVDP Compliance Campaign to Enforce Reporting

At Golding and Golding, we focus exclusively on IRS offshore compliance.  For many years, we routinely represented people in all aspects of OVDP (offshore voluntary disclosure program). 

Post OVDP Compliance Campaign

This program was terminated by the IRS in September 2018 – and the prior VDP (Voluntary Disclosure Practice) was expanded — in which we are currently representing many clients with navigating this much more complex (but sometimes more forgiving) tax amnesty program.

IRS OVDP Compliance Enforcement

But, that does not mean that the IRS is slowing down enforcement of offshore disclosure compliance

Why would the IRS want to slow down, when they can try to issue penalties upwards of 50% maximum value of unreported accounts (FBAR penalties)– without even considering all the other penalties they can issue.

Did You Complete OVDP & Sign a 906?

Once you complete the OVDP program and sign a form 906, you have essentially closed the case.

But, that does not mean your offshore reporting is over. Rather, all that means is that you can now safely begin disclosing your foreign income, assets, investments, and accounts without concern that you may get hit with Criminal penalties for making a quiet disclosure.

IRS New Practice Group: “Post OVDP Compliance”

The IRS recently created a new practice group directed towards en ensuring “Post-OVDP” compliance.

As provided by the IRS:

Practice Area: Withholding & International Individual Compliance


Lead Executive: John Cardone, director of Withholding & International Individual Compliance


U.S. persons are subject to tax on worldwide income. This campaign addresses tax noncompliance related to former Offshore Voluntary Disclosure Program (OVDP) taxpayers’ failure to remain compliant with their foreign income and asset reporting requirements.


The IRS will address tax noncompliance through soft letters and examinations.

Out of Compliance (Pre or Post-OVDP)

If you are out of IRS Offshore Compliance — either before or after submitting an OVDP — you have options.

Golding & Golding – Board Certified in Tax Law

Golding & Golding represents clients worldwide in over 70-countries exclusively in Streamlined, Offshore and IRS Voluntary Disclosure matters. We have successfully completed more than 1000 streamlined and voluntary disclosure submissions.

Our Team Lead is a Board Certified Tax Law Specialist (Less than 1% of Attorneys nationwide) and Enrolled Agent, with a Master’s of Tax Law (LL.M.)

Mr. Golding leads his team in each and every case we accept for submission.

We are the “go-to” firm for other Attorneys, CPAs, Enrolled Agents, Accountants and Financial Professionals worldwide.