Skip to Main Content

Scott Michel Comments on Closure of IRS Offshore Voluntary Disclosure Program

March 23, 2018, MLex US Tax Watch

The Internal Revenue Service announced March 13 that it will be ending the 2014 Offshore Voluntary Disclosure Program (OVDP) on Sept. 28.

. . .

While the winding down of the OVDP didn't come as a total surprise, there is some concern about what shape a post-Sept. 28 voluntary disclosure process will take. Scott D. Michel of Caplin & Drysdale noted that the traditional CI Voluntary Disclosure Practice has been in place for many years (dating back to the early 1950s), but he said the IRS has provided very little guidance on it.

Section of the Internal Revenue Manual describes what constitutes a timely disclosure and lays out several methods for providing disclosures, but those rules aren't comprehensive or clear-cut, Michel said.

However, the IRS's request for suggestions on future Voluntary Disclosure Practice procedures is an encouraging sign, he said. "This is an opportunity for the tax bar that practices in this area to really put its heads together and suggest a uniform, efficient and easy-to-understand voluntary disclosure procedure that practitioners can rely on in the future," said Michel.

For the full article, please visit MLex’s website (subscription required).

Excerpt taken from the article “IRS winding down Offshore Voluntary Disclosure Program” by Kristen Parillo for MLex.


About Caplin & Drysdale
Celebrating our 55th Anniversary in 2019, Caplin & Drysdale continues to be a leading provider of legal services to corporations, individuals, and nonprofits throughout the United States and around the world. We are also privileged to serve as legal advisors to accounting firms, financial institutions, law firms, and other professional services organizations.

The firm's reputation over the years has earned us the trust and respect of clients, industry peers, and government agencies. Moreover, clients rely on our broad knowledge of the law and our keen insights into their business concerns and personal interests. Our lawyers' strong tactical and problem-solving skills -- combined with substantial experience handling a variety of complex, high stakes, matters in a boutique environment -- make us one the nation's most distinctive law firms.

With offices in New York City and Washington, D.C., Caplin & Drysdale's core practice areas include:
For more information, please visit us at
Washington, DC Office:
One Thomas Circle NW
Suite 1100
Washington, DC 20005
New York, NY Office:
600 Lexington Avenue
21st Floor
New York, NY 10022


This communication does not provide legal advice, nor does it create an attorney-client relationship with you or any other reader. If you require legal guidance in any specific situation, you should engage a qualified lawyer for that purpose. Prior results do not guarantee a similar outcome.

Attorney Advertising
It is possible that under the laws, rules, or regulations of certain jurisdictions, this may be construed as an advertisement or solicitation.
©2021 Caplin & Drysdale, Chartered
All Rights Reserved.