Alexey Manasuev featured in Advo​cateDai​ly​.com — Taxpayers likely face less favourable options after U.S. OVDP closes

Author(s): Advo​cateDai​ly​.com staff The fol­low­ing arti­cle first appeared in Advo​cateDai​ly​.com,  May 27, 2018.

The U.S. Inter­nal Rev­enue Ser­vice (IRS) is clos­ing a pro­gram lat­er this year that allowed cer­tain tax­pay­ers to come for­ward to report undis­closed off­shore income — which will like­ly leave those who wish to become com­pli­ant with less advan­ta­geous options, Oakville-based U.S. tax attor­ney Alex­ey Man­a­suev tells Advo​cateDai​ly​.com. Ear­li­er this year, the IRS announced that it is ramp­ing down it’s Off­shore Vol­un­tary Dis­clo­sure Pro­gram (OVDP), and will close it on Sept. 28. The OVDP pro­vides an oppor­tu­ni­ty for delin­quent tax­pay­ers with undis­closed income from off­shore accounts to become com­pli­ant and to avoid crim­i­nal pros­e­cu­tion. How­ev­er, appli­cants must agree to pay a mis­cel­la­neous off­shore penal­ty and oth­er applic­a­ble fines — such as accu­ra­cy-relat­ed, fail­ure-to-file and fail­ure-to-pay penal­ties, says Man­a­suev, prin­ci­pal of U.S. Tax IQ. The mis­cel­la­neous off­shore penal­ty may equal 27.5 per cent, or 50 per cent of the high­est aggre­gate val­ue of undis­closed assets dur­ing the years cov­ered by the OVDP. “The OVDP usu­al­ly sup­pos­es that a can­di­date and appli­cant may have some expo­sure to crim­i­nal pros­e­cu­tion or may poten­tial­ly have wil­ful con­duct in not com­ply­ing with U.S. tax fil­ing and report­ing require­ments. So, the OVDP his­tor­i­cal­ly, and as it exists now, has been the option for those tax­pay­ers who have to wor­ry about poten­tial crim­i­nal pros­e­cu­tion,” says Man­a­suev .…

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