From the Tax Law Offices of David W. Klasing - IRS LB&I Announces Post OVDP Compliance Campaign, Signaling Danger for Taxpayers with Unreported Taxable Foreign Income or Non-Compliant U.S. International Information Reporting
To address these issues in an organized and efficient manner, LB&I has launched an assortment of compliance campaigns which we reported on in 2018 with a follow-up this July. Many of these are focused specifically on international tax issues. For instance, the Foreign Earned Income Exclusion (FEIE) Campaign targets taxpayers who improperly claimed the FEIE despite lacking eligibility. LB&I has also launched a FATCA compliance campaign, which targets "entities that have FATCA reporting obligations but do not meet all their compliance responsibilities," such as filing Form 8938 (Statement of Specified Foreign Financial Assets), under the Foreign Account Tax Compliance Act. Simultaneously, the Offshore Private Banking Campaign targets U.S. taxpayers who may not have complied with U.S. "income tax and information reporting requirements associated with… offshore investment and business activities."
"U.S. persons are subject to tax on worldwide income. This campaign addresses tax noncompliance related to former Offshore Voluntary Disclosure Program (OVDP) taxpayers' failure to remain compliant with their foreign income and asset reporting requirements. The IRS will address tax noncompliance through soft letters and examinations."