You Received an OVDP Closing Letter – Must You Sign it?

You Received an OVDP Closing Letter – Must You Sign it?

OVDP is the Offshore Voluntary Disclosure Program.

For most individuals, they enter Offshore Voluntary Disclosure Program because they were willful (a.k.a. knowingly or intentionally) failed to report foreign income, investments, assets, or foreign accounts.

OVDP is a comprehensive process, but like everything in life at some point it will come to an end. And when it does, you will receive the Closing Letter “906”.

What is a Closing Letter?

The closing letter is essentially a letter from the Internal Revenue Service letting you know that if you agree to the terms and conditions of the program, the IRS is willing to close the matter for you.

By signing and returning the letter to the IRS, you lose your right to fight the penalties that are being issued under OVDP.

But I Disagree with the Penalty Amount?

This is not uncommon. For some people, they entered the program before 2014, were non-willful, and were unaware that the Internal Revenue Service developed transitional treatment to assist non-willful applicants transition to the streamlined program (which did not come into effect until July 2014)

Alternatively, a person may have entered the program based on bad advice they received from counsel who did not understand the ramifications of entering OVDP.  For these individuals, if they submitted under OVDP after July-2014 they cannot attempt to transition to the streamlined program. Why? Because since the Streamlined Program was available at the time they entered OVDP, they do not get a chance to go back for a “do-over.”

Golding & Golding, A PLC

We have successfully represented clients in more than 1,000 streamlined and voluntary disclosure submissions nationwide and in over 70-different countries.

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

 

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