The IRS ended its Offshore Voluntary Disclosure Program (OVDI) on Sept. 28, 2018, and recently announced new internal procedures for taxpayers who wish to avoid criminal prosecution for domestic or offshore tax evasion conduct. These new procedures are far less “taxpayer friendly” and signal a return to the way voluntary disclosures were handled prior to OVDI.

The new voluntary disclosure rules do not affect the existing Streamlined Filing Compliance Procedure, Delinquent FBAR Filing Procedure, or Delinquent Information Returns Filing Procedures available to taxpayers with “non-willful” foreign compliance issues.