In the five years since the Internal Revenue Service announced the first Offshore Voluntary Disclosure Program (OVDP) in March 2009, almost 45,000 taxpayers have elected to participate and IRS has collected $6.5 billion.

On June 18, the IRS announced major changes to the terms of the OVDP. These apply to all persons not already participating on that date. In some cases, the changes make compliance less onerous but, for other taxpayers, the ante has been significantly raised.