Improvements Are Needed in Offshore Voluntary Disclosure Compliance and Processing Efforts

The Commissioner, Large Business and International (LB&I) Division, should have all denied or withdrawn offshore voluntary disclosure requests identified in this report reviewed for FBAR penalty assessments and possible referral to CI.

The Commissioner, Large Business and International (LB&I) Division, and the Chief, Criminal Investigation (CI), should develop procedures to require the immediate review of any future denied or withdrawn offshore voluntary disclosure requests for further compliance actions.

The Commissioner, Large Business and International (LB&I) Division, and the Chief, Criminal Investigation (CI), should centrally track and control taxpayer offshore voluntary disclosure requests in the OVDP Unit starting with the initial taxpayer request (preclearance) to join the program.

The Commissioner, Large Business and International (LB&I) Division, and the Chief, Criminal Investigation (CI), should establish one mailing address for taxpayers to use for submitting their offshore voluntary disclosure requests and related documentation.

The Commissioner, Large Business and International (LB&I) Division, and the Chief, Criminal Investigation (CI), should ensure that employees adhere to established timeliness guidelines for taxpayers to respond to offshore voluntary disclosure-related correspondence and follow those guidelines during the initial eligibility determination, case building, and certification processes.