The 2017 Tax Cut and Jobs Act (TCJA) had many provisions, which we will be discussing over the next few months, and they include good, bad, and ugly. Some are two-faced, with aspects that at first seem bad but may actually turn out to be a blessing depending on your situation. One such provision is the GILTI regime, a new category of “Subpart F” income intended to prevent inappropriate deferral of foreign source income by U.S. taxpayers.

On March 13, 2018, The Internal Revenue Service (IRS) announced that the OVDP will be ending September 28, 2018, and that any submissions not fully completed by that date will be rejected from the program. This means that anyone who has started but not fully complied with the documentation requirements by then will not be able to take advantage of the program and will instead be required to use the standard voluntary disclosure submission rules, which are not as friendly.