In past offshore voluntary disclosures initiatives under the famed OVDI program – the IRS has continually adjusted the information it seeks from Taxpayers.
The IRS has just come out with formal IRS Forms to take the place of the Word documents used before. The new forms are:
Form 14457 – Offshore Voluntary Disclosure Letter
Form 14454 – Offshore Voluntary Disclosure Program Letter Attachment
The information requested in these disclosures is used, in my view, for three central purposes:
1) Provide information to the IRS regarding the Taxpayer to be able to confirm that the person is eligibile for the program
2) Begin to collect information for the examiner to help guide his/her investigation
3) Collect data for purposes of ensnaring promoters of offshore evasion.