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For U.S. taxpayers who have not yet disclosed foreign accounts and who are trying to decide what to do, a review of the related Offshore Voluntary Disclosure Program statistics is often helpful.

As of late 2013, the United States Department of Justice had indicted approximately 120 taxpayers or taxpayer advisors in relation to a failure to report income from or the existence of foreign financial accounts. The average related tax loss is approximately $2.3 million, with an average incarceration rate of roughly fourteen months. Had these taxpayers disclosed their foreign accounts through one of the IRS Offshore Voluntary Disclosure programs, the outcome would likely have been much different.

Information about OVDP

The Government Accountability Office has released statistical data on the various IRS Offshore Voluntary Disclosure Programs in a report titled Offshore Tax Evasion, available here. From over 39,000 taxpayer disclosures, the IRS collected over $5.5 billion in revenues. Disclosures from the 2009 OVDP resulted in the following statistics:

  • Nearly all program participants were assessed the standard 20% miscellaneous OVDP penalty, available under the 2009 program only. Taxpayers that were assessed the 20% penalty had account values exceeding $75,000.
  • The median account balance of the cases processed within the 2009 OVDP was $570,000.
  • Only about six percent of the 2009 OVDP cases resulted in miscellaneous penalties in excess of $1 million.
  • More than half of the taxpayers from the 2009 OVDP had accounts at UBS in Switzerland.

Do You Need an OVDP Attorney?

At Brown, PC, our team of experienced tax professionals has completed numerous disclosures in the 2009, 2011, and 2012 OVDP programs. We can help you assess your risk and create a disclosure strategy that will protect you from criminal prosecution and minimize your financial loss. Contact our team of knowledgeable offshore account compliance attorneys at 817-870-0025 or toll free at 888-870-0025 to discuss your foreign account disclosure options and to schedule a highly confidential consultation.

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