The OVDP is a partial tax amnesty that allows Americans, green card holders and all other US taxpayers to subsequently report previously undisclosed foreign financial accounts and thus to be subject to lower sanctions than in the event of continued non-disclosure. The tax returns for the last three years and the related Report of Foreign Bank and Financial Accounts for the last seven years must be submitted to the IRS.
Those affected should continue to use the OVDP until August 29, 2018 to take advantage of the tax amnesty. At present, it cannot be ruled out that otherwise, US income may be taxed without a time limit, and flat-rate fines of USD 5,000 per assessment period may have to be paid. We would be pleased to assist you with timely declaration.
In the meantime, banks and insurance companies have started to ask their customers whether they are US citizens or are subject to US tax liability for other reasons. In this connection, they must fill out tax form W-9 or W-8BEN. This information is passed on to the IRS, so that the IRS will have far more detection options. If no Form W9 or Form W-8BEN has been submitted, withholding tax of 30% will be withheld when funds from the USA flow into financial accounts abroad.