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Watch Out for the IRS Offshore Voluntary Disclosure Bait-and-switch

If your creepy uncle, known for bad behavior with underaged girlfriends, bought an ice cream truck, you’d not trust him to limit himself to selling ice cream.

Last year the Taxpayer Advocate’s Office tried to force the IRS to stop luring people who have foot-faulted their foreign account reporting obligations with the promises of leniency, and then reneging and stomping them with big fines.  Now IRS Commissioner Shulman has reopened his ice cream stand:
The Internal Revenue Service [has] reopened the offshore voluntary disclosure program to help people hiding offshore accounts get current with their taxes and announced the collection of more than $4.4 billion so far from the two previous international programs.
The IRS reopened the Offshore Voluntary Disclosure Program (OVDP) following continued strong interest from taxpayers and tax practitioners after the closure of the 2011 and 2009 programs. The third offshore program comes as the IRS continues working on a wide range of international tax issues and follows ongoing efforts with the Justice Department to pursue criminal prosecution of international tax evasion.  This program will be open for an indefinite period until otherwise announced.
Should taxpayers who want to come clean on reporting their foreign financial accounts come clean?  That’s between them and their advisors, but they will surely consider this from the Taxpayer Advocate’s Office when it tried to force the IRS to abide by the original terms of its 2009 Offshore Voluntary Disclosure Program, saying the IRS bait-and-switch…
…burdened taxpayers, wasted resources, violated longstanding IRS policy, opened the IRS to potential legal challenges, and was not properly disclosed as required by FOIA. It also damaged the IRS's credibility with taxpayers as well as the practitioner community. As a result, the IRS is likely to have more difficulty gaining participation in any future settlement initiatives. This erosion in trust for the IRS among taxpayers and practitioners is also likely to have a negative impact on IRS's mission and voluntary tax compliance more generally.
So, who wants some ice cream?