Tax Analysts has obtained, via a FOIA request, the current hotline guide to IRS questions and interpretations of the rules governing its offshore voluntary disclosure program and its streamlined filing compliance procedures.
According to Tax Notes, in the undated 30-page document , the IRS addresses many issues, including those involving the transition rules following the 2014 changes to the program, interplay with foreign bank account reporting guidance, joint filing, foreign pensions, and streamlined submissions without Social Security numbers. The release also has a list of talking points that were provided to revenue agents following the 2014 changes.
Stakeholders hoping for significantly greater insight into the IRS’s thinking behind OVDP and the streamlined procedures – which have collectively brought in more than $ 10 billion in taxes, interest, and penalties – may be disappointed, however. The guide does not offer much more information beyond what practitioners already knew.
Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal.