LB&I’s campaigns are an audit strategy added in 2017 to improve return selection, identify issues representing a risk of noncompliance, and make the greatest use of its limited resources.
In another OVDP related development, in November 2019), the IRS added the following:
Post Offshore Voluntary Disclosure Program (OVDP) Compliance
Practice Area: Withholding & International Individual Compliance
Lead Executive: John Cardone, director of Withholding & International Individual Compliance
U.S. persons are subject to tax on worldwide income. This campaign addresses tax noncompliance related to former Offshore Voluntary Disclosure Program (OVDP) taxpayers’ failure to remain compliant with their foreign income and asset reporting requirements. The IRS will address tax noncompliance through soft letters and examinations.See IRS website for its active campaigns, here.
JAT Comment: One of the traditional goals of the IRS's voluntary disclosure programs is not only to resolve past issues but, put the taxpayers involved on a track of ongoing compliance, not only with respect to offshore accounts but their tax obligations generally. It is not clear whether these initiatives will focus narrowly on the compliance issue identify but might sweep more broadly to identify general noncompliance.
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