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OVDP stands for Offshore Voluntary Disclosure Program, an initiative by IRS under which U.S. taxpayers with unreported offshore financial accounts can come in from the cold, avoid criminal prosecution and pay a substantial but reduced civil penalty for not filing FBARS (Foreign Bank Account Reports).  In her annual report to congress, the National Taxpayer joined others who have criticized certain aspects of the OVDP (See The Tax Wars Blog “”OVDP Update – Taxpayer Advocate Critical of Opt-Out Rules.” at ).  This lyric parodies some of these issues with the OVDP.  PFIC means Passive Foreign Investment Company, a foreign entity subject to extremely complex and onerous tax rules.

(To tune of “Tonight,” by Leonard Bernstein and Stephen Sondheim, from, “West Side Story).

A voluntary plea
I wanted to come in from the cold

You promised certainty
Seems your word is more tinsel than gold

I thought  would be forgiven
Into a herd we’re driven
Of culpability

The room is crammed
Both innocent and damned
In OV-

Refrain Verses:
My head was in the stars
What did I know of FBARS the while?

My head was in the clouds
Never read, my return, when I’d file

The deal
You sold me seemed terrific
Until you brought up PFIC
To up the tab on me

Now fear, now doubt
And whether to opt-out
Of OV-

Lyric © 2012 by Robert S. Steinberg, Esquire
All rights reserved


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