By Christopher M. Ferguson
Tax Insider (October 25, 2018)
The recent end of the OVDP is not the end of IRS enforcement of undisclosed offshore accounts. For most of the past decade, the IRS has maintained a safe harbor for taxpayers who want to disclose offshore account holdings that may otherwise expose them to criminal penalties, and over the years, tens of thousands of taxpayers have availed themselves of the program. But on Sept. 28, the world changed for those who have not yet revealed their foreign accounts to law enforcement.