The Offshore Voluntary Disclosure Program (OVDP) was created by the IRS in 2009 to try to convince U.S. connected individuals to voluntarily come forward and report foreign accounts which they had not declared before. Those participating in OVDP would have their penalties limited in exchange for coming forward and reporting funds, and would be provided with protection from criminal prosecution.

If you are a U.S.-affiliated person and you have accounts offshore with funds totaling $10,000 in aggregate at any point over the year, you are supposed to file an annual Report of Foreign Bank and Financial Account (FBAR). June 30, 2016 was the deadline for filing this year. Many taxpayers have discovered this requirement only recently, which left taxpayers who wanted to comply with the law wondering what their best options were.