International Financial Law Prof Blog

Editor: William Byrnes
Texas A&M University
School of Law

Saturday, January 24, 2015

Offshore Voluntary Disclosure Program's Non-Willful Narratives

Offshore Voluntary Disclosure Program

Alison Bennet of Bloomberg Law reports that the IRS's 2015 versions of the two strealined procedures OVDP forms (Form 14653 and Form 14654) require taxpayers to "provide a “narrative statement of facts” explaining their failure to disclose their offshore assets, or the agency will consider the applications incomplete and the taxpayer won't get penalty relief."

The forms—Form 14653 (used by non-residents) and Form 14654 (used by US residents)—are for taxpayers to certify that their conduct was not willful, a prerequisite to qualifying for little to no penalties.

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Prof Byrnes,
i have had personal experience in one of my client's case, where the revenue officer is not satisfied with a detailed statement of facts along with one line explaining why it is nonwilful. So, now we are providing a more detailed explanation of non-willfulness.

Posted by: NEERAJ BHATIA, CPA | Jan 27, 2015 10:38:19 PM

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