2011 Oct 17 – Michel

 
Scott D. Michel / Mark E. Matthews
OVDI is over — What’s next for voluntary disclosures?
Tax Notes 133 (17 Oct 2011) 369-378

https://docs.google.com/file/d/0B0SLTNWD-Z3YNjg0MGJmMjUtMDk1NS00NmQ5LWI1MTgtYTNmYTljZDI3NTJh/edit?hl=en_US&pli=1

“The essence of OVDI was to leverage a civil penalties deal into the VDP.” In the OVDI programs, “stereotypical offshore tax cheats” were few in number. A large group in OVDI 2009 had accounts gifted by or inherited from parents or other relatives. A large group in OVDI 2011 had lived abroad for many years, had routine foreign financial accounts, and complied with taxation in country of residence. Unwillingness to become US tax compliant manifests “most dramatically in Canada, with its hundreds of thousands of U.S. citizens.” [Footnote 5 details a “significant increase” in persons seeking to expatriate.] The article closes with eight specific recommendations for future disclosure, and recognizes that implementation of FATCA may render the issue irrelevant. Nine footnotes.