![](https://www.taxconnections.com/taxblog/wp-content/uploads/TaxConnections-Picture-Q-and-A-square5.jpg?resize=90%2C90&ssl=1)
Answers to the Most Frequently Asked Questions Regarding OVDP
As a tax attorney specializing in the Offshore Voluntary Disclosure Program (OVDP), nary a day goes by that I don’t get a call from a person inquiring about the OVDP. The questions asked are relatively the same. After a while, I began to make a list of the most frequently asked questions. Below are my answers to them: (continued)
XVIII. How can the IRS propose adjustments to tax for more than three years without either an agreement from the taxpayer or a statutory exception to the normal three-year statute of limitations for making those adjustments?
Agreeing to assessment of tax and penalties for all voluntary disclosure years is part of the resolution offered by the IRS for resolving offshore voluntary disclosures. The taxpayer must agree to assessment of the liabilities for those years in order to get the benefit of the reduced penalty framework. It is an all or nothing proposition.
Next: XIX. Must I complete and sign agreements to extend the period of time to assess tax – including tax penalties – and to assess FBAR penalties for any years that are set to expire while my application is being processed?
In accordance with Circular 230 Disclosure
Recent Comments