Individuals with foreign financial accounts over certain thresholds must include the earnings as income on their tax returns and report the accounts annually or face serious tax penalties. In 2009, the IRS commenced a program to encourage taxpayers who had failed to comply with reporting requirements to come forward voluntarily; the current version of the program began in 2014. The program, called the Offshore Voluntary Disclosure Program (OVDP), is winding down and will be closed on September 28, 2018 (IR-2018-52, 3/13/18). Taxpayers with undisclosed foreign financial assets are urged to come forward and use the OVDP before the program closes.
To date, more than 56,000 taxpayers have taken advantage of the program. However, the number of taxpayers using the program has declined considerably, with only 600 disclosures in 2017. Although the OVDP is ending, the IRS will continue to use other tools to combat offshore tax avoidance, including taxpayer education, whistleblower leads, audits, and criminal prosecution.
Depreciable property used in a trade or business and held for more than a year. All Section 1231 gains and losses are netted; a net gain is treated as capital gain, a net loss as an ordinary loss.