Attached is a very interesting article from Bloomberg, which discussed the recent OVDI programs for FBAR compliance. Nina Olson, National Taxpayer Advocate, discusses how the program is highly beneficial to those who were intending to hide assets overseas. However, the program is looked at by many as punitive to those who only negligently failed to file FBAR Forms and report the underlying taxable income.
The good news is taxpayers still have options to get into compliance with their reporting obligations. Whether or not they take advantage of the program depends on the facts of each individual case. The recent programs, have brought a signigicant amount of revenue into the goverment coffers.