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Form 14454 carries a name that no longer matches the program: the Attachment to Offshore Voluntary Disclosure Letter, from an OVDP the IRS closed on September 28, 2018. Many teams still use it internally, though, because it remains a clean account-by-account workpaper for today's Voluntary Disclosure Practice.
The discipline is one form per foreign financial institution, completed for every account you control or beneficially own, with the institution name and account number on lines 1a-1b, the account-open date on line 3, and the advisors or facilitators on lines 5 through 7. The official intake now runs on Form 14457, with Part I preclearance followed by Part II within 45 days and one 45-day extension possible, so build your 14454-style schedules before you request preclearance.
Key Takeaways
- Form 14454 is the legacy “Attachment to Offshore Voluntary Disclosure Letter.” Many teams still use it internally to document each undisclosed foreign account for today’s Voluntary Disclosure Practice, which formally runs on Form 14457.
- You complete a separate Form 14454 workpaper per account or per institution, record opening and closing dates, identifiers, and the people or entities who facilitated the account. Keep this alongside your FBAR and return schedules.
- The current Voluntary Disclosure Practice runs on Form 14457, with Part I preclearance followed by Part II within 45 days and only one 45‑day extension possible. Build your 14454‑style schedules before you request preclearance, or you will run out of time.
- You must file a separate Form 14454 for each foreign financial institution; a single form cannot cover multiple institutions. Complete it for every foreign account you control or are a beneficial owner of, and keep it with your FBAR and return schedules.
- OVDP closed in 2018, and Form 14457 is now the official intake. Legacy attachments like 14454 still reflect what examiners expect to see, especially around facilitators and account history.
What Form 14454 Is, And Who Uses It In 2026
Form 14454 is titled “Attachment to Offshore Voluntary Disclosure Letter.” It was designed to capture one financial institution at a time, along with the account number, open and close dates, and the people who helped open or manage the account, including bankers, advisors, or nominees. In practice, you prepare one per institution or account so a reviewer can scan facts fast (the form itself requires a separate attachment for each financial institution, so never combine multiple institutions on a single one). Although VDP now uses Form 14457 for preclearance and application, the 14454 template remains a practical way to standardize details and avoid rework.
Important context for you, the program name changed, the discipline did not. The IRS Voluntary Disclosure Practice is still a two‑step gateway. You file Part I of Form 14457 to seek preclearance, then you must submit Part II within 45 days. If CI approves preliminary acceptance, your case moves to a civil examiner who will expect complete returns, FBARs, and support. That is where tight, 14454‑style workpapers make the exam smoother.
Quick truth, standardize early. Build a per‑account 14454 workpaper before preclearance so you can certify facts confidently when Part II is due.
Where Form 14454 Fits On Today’s Timeline
Here is the current, real‑world sequence that firms use for offshore voluntary disclosures in 2026.
- Preclearance, submit Form 14457 Part I. Wait for CI to confirm timeliness and eligibility.
- Part II deadline, within 45 days after preclearance. One 45‑day extension may be granted on a case‑by‑case basis, no more. This is why your account‑by‑account facts must be ready.
- Preliminary acceptance, CI issues the letter and forwards your file for civil processing. Examiners then request returns, FBARs, and support for the disclosure period, generally the most recent six years.
The discipline is the same throughout: the more complete your per-account records are before preclearance, the smoother the civil examination runs. Confirm current Voluntary Disclosure Practice timing and any procedural changes against the IRS instructions in effect for your case before you rely on them.
Data To Gather For Each Account
Think in layers, identifiers, chronology, movements, people.
- Institution profile, full legal name, branch address, country, any DBA. Account number and type. Open date (never leave this blank; if the exact date is unknown, record a good-faith estimate and mark it as one), close date.
- Ownership and control, you as owner or signatory, plus any entity or nominee that touches ownership. Capture legal name, jurisdiction, and tax IDs where available.
- Movements that matter, year‑by‑year high balances, deposits from the United States, transfers to the United States (for each transfer, capture the institution and location, the name on the account, the amount, and the date, not just the institution name), and narrative context for spikes or closures. Align these with FBAR and return schedules once the exam begins.
- People and facilitators, banker or relationship manager, external advisors, and anyone who suggested specific practices, for example, hold mail, meet outside the U.S., move funds between institutions. The legacy 14454 questions are a good prompt list.
Keep a cross‑reference log that ties each account’s workpaper to, one, the relevant FBAR, two, the amended return schedules, and three, any wires or brokerage reports that support the high balance and flow figures. When a civil examiner calls, you will answer questions with documents in hand.
How To Complete A 14454‑Style Workpaper Without Statements
You might not have every statement on day one. That should not stop you from building accurate year‑by‑year figures with transparent sourcing. The IRS encourages you to be ready before you even seek preclearance on Form 14457, Part I.
Four Steps That Keep You Accurate
| Step | Action | What good looks like |
| 1 | List every foreign account with clean identifiers | Institution’s full legal name, branch address, country, account number, open and close dates, owner or signatory role. |
| 2 | Compute each year’s highest value, mark estimates | Use best available records, interim statements, bank letters, or brokerage summaries, then flag any estimates and keep your math file. |
| 3 | Record U.S.‑related deposits and transfers | Track inflows from the U.S., outflows to the U.S., and a short explanation for unusual spikes. |
| 4 | Name facilitators and attach contact details | Banker names, titles, branch, email if known, and any advisor or nominee tied to the account. |
Tip, create a one‑page “source sheet” per account. List every document you used, with file names and dates. When an examiner asks, you can answer in seconds.
The Signature And Certifications To Expect
During intake you complete Form 14457, not 14454, but the facts you assemble on your 14454‑style workpapers flow into Part II. The IRS confirms that Part II must be submitted electronically within 45 days after preclearance, and that only one 45‑day extension is available. Expect to certify truthfulness, cooperate, and acknowledge willful conduct as part of VDP.
Once CI issues preliminary acceptance and forwards your case for civil processing, examiners apply the VDP framework in the IRM, which typically uses a six‑year disclosure period and requires you to submit all returns and reports for that period to the assigned examiner. That is when your per‑account schedules, FBAR confirmations, and amended returns must line up.
Why Early Data Assembly Pays Off
Once CI issues preliminary acceptance, the civil examiner expects all returns, FBARs, and supporting records for the disclosure period in short order, so the work you do up front decides how smoothly the case closes. Assemble your per-account 14454-style workpapers before preclearance, and confirm the current Voluntary Disclosure Practice deadlines and payment requirements against the IRS instructions in effect for your case before you commit to a timeline.
Common Mistakes And Easy Fixes
Most 14454 problems are not about the numbers, they are about completeness. The same gaps surface across packages every season, and each one slows the examiner and invites follow-up questions.
What, How, Wow, The Framework That Keeps You Moving
- What, a per‑account profile that captures identifiers, chronology, flows, and people.
- How, use a 14454‑style workpaper for each account or institution, tie it to FBAR and amended return schedules, and keep a source sheet.
- Wow, be examiner‑ready. When the civil team calls, you can hand over a complete package that mirrors the IRS’s expectations in the IRM for VDP cases, including the common six‑year disclosure horizon.
Security And Workflow Notes For CPA Firms
If you handle sensitive offshore matters, keep file access on need‑to‑know roles, use encrypted exchange, and log activity for every account package. I encourage firms to work inside their own systems, for example, Karbon, Canopy, or TaxDome, with zero local storage and standardized naming so reviewers can find what they need without hunting.
A brief note on how we help, Accountably integrates trained offshore teams into your workflow with SOPs, file naming standards, and review layers that reduce partner time in review. That structure matters when the clock starts on VDP deadlines and every attachment must be right the first time. Use us for disciplined execution, not for legal advice.
A Simple Checklist You Can Use Today
- Build one 14454‑style workpaper per foreign account or institution, capture identifiers, chronology, flows, and facilitators.
- Tie each workpaper to the FBAR and to every amended or delinquent return schedule you expect to file during the exam.
- Validate year‑by‑year high balances, mark estimates, and keep a source sheet per account.
- Preclear only when your Part II facts are already assembled, because your 45‑day clock starts immediately after preclearance.
- Confirm the current Voluntary Disclosure Practice deadlines and payment requirements against the IRS instructions in effect for your case, and plan cash accordingly.
Reusable Checklists
Drop these straight into your firm SOP library. Each one mirrors a section of Form 14454 so a preparer and a reviewer can work from the same list, account by account.
Per-account 14454 profile
- Record the foreign financial institution name and account number on lines 1a-1b.
- Enter the account address and country on line 2.
- Put the account-open date on line 3, using a labeled estimate if the exact date is unknown.
- Answer line 4a (still open) and, only if the answer is No, the close date on line 4b.
- Name every advisor or facilitator who helped open or use the account on line 5.
- Confirm the page header shows your name, last four TIN digits, institution name, and account number on all five pages.
Communications and facilitator review (lines 6 to 9)
- Detail each communication on line 6a with the date, the person, and the form (call, email, fax, or meeting).
- Flag any contact made while you were in the U.S. on lines 6b-6c and name the organization involved.
- Walk lines 7a through 7g for any advice to conceal, hold mail, or meet outside the U.S.
- List the documents you received, who showed them, and which you retained on lines 8a-8c.
- Confirm on line 9 whether deposits or withdrawals ran through a U.S. branch of the institution.
Movement and affiliate schedule (lines 10 to 15)
- Complete lines 10b-10e for every deposit beyond the opening deposit when 10a is Yes.
- Complete lines 11b-11e for every withdrawal when 11a is Yes.
- Answer lines 12a-12d for funds moved into the United States, including the line 12c schemes question.
- Record cross-border moves to another jurisdiction on lines 13a-13b.
- Identify affiliated individuals on lines 14a-14b and affiliated entities across lines 15a-15i.
- For each transfer field (10e, 11e, 12d, 13b), capture the institution and location, the name on the account, the amount, and the date.
Keep 14454 Season From Stalling
Offshore voluntary disclosure work does not arrive on a tidy April calendar, it lands whenever a client surfaces an account they should have reported years ago. Each foreign financial institution needs its own Form 14454, and the IRS itself budgets roughly two hours per form in its Paperwork Reduction Act notice, before you have reconstructed a single year of balances or traced one transfer.
The bottleneck is rarely the form, it is the evidence behind it. Senior reviewers lose hours chasing missing open dates, half-listed transfers, and facilitator names that should have been captured the first time. A repeatable intake structure clears most of that before it reaches review.
- Open one workpaper per institution at intake, so lines 1a-1b and the line 3 open date are never reconstructed twice.
- Standardize the transfer schedule so lines 10e, 11e, 12d, and 13b always carry the institution, name on account, amount, and date.
- Pre-build the respondent grid (Taxpayer, Spouse, Related entities) so no yes/no item on lines 6 through 13 ships with a blank column.
- Track each open file against the VDP Part II clock that starts at preclearance, so account schedules are ready before the deadline runs.
That structure is exactly what we build for teams handling sensitive disclosure work. Accountably integrates trained, U.S.-led offshore staff into your tax workflow with documented SOPs, file-naming standards, and layered review, so account histories are assembled once and stand up when the examiner calls. We deliver the production discipline, your team keeps the judgment and the client relationship.
FAQs
Is OVDP still open in 2026?
No. The Offshore Voluntary Disclosure Program closed on September 28, 2018. Today you use the IRS Voluntary Disclosure Practice, which runs through Form 14457 for preclearance and application. Legacy attachments like Form 14454 remain useful as working papers to organize account details.
Do I submit Form 14454 with my VDP application?
The current official intake is Form 14457, Parts I and II. Many practitioners still prepare 14454‑style schedules for each account and include that information in the package sent to the civil examiner after preliminary acceptance, because it answers the questions examiners typically ask about institutions, movements, and facilitators.
Can one Form 14454 cover several foreign accounts?
No. You must complete a separate Form 14454 for each foreign financial institution; a single form cannot cover multiple institutions. Complete one for every foreign account you control or are a beneficial owner of, and carry the institution name and account number into lines 1a and 1b on each.
How many years are usually in scope?
Under the IRM’s VDP framework, the disclosure period generally covers the most recent six years, with all returns, information returns, and reports submitted to the assigned examiner. Confirm scope with your examiner based on the facts in your case.
What deadlines should I plan around right now?
The key clock under the Voluntary Disclosure Practice is the Part II deadline: submit Part II within 45 days after preclearance, with only one 45‑day extension possible. Build your account schedules before you seek preclearance, and confirm current VDP deadlines and payment requirements against the IRS instructions in effect for your case.
Do bank statements have to be attached with the initial submission?
The IRS stresses being document‑ready when you apply, and you submit Form 14457 electronically on intake. In practice, most supporting statements are delivered once the civil examination starts, so teams use 14454‑style schedules to present accurate figures and then provide statements when requested by the examiner under the IRM process.
What is IRS Form 4549 used for?
Form 4549 is the Income Tax Examination Changes report. It summarizes the agent’s proposed adjustments, penalties, and interest, and you sign to agree or you respond to dispute the changes through the appropriate channels.
Does a W‑9 need to be signed?
Yes. A W‑9 requires a signature, including acceptable electronic methods, to certify the taxpayer identification number and backup withholding status. Keep a copy for your records.
Should I do VDP if my issue might be non‑willful?
VDP is designed for willful conduct. If your facts are non‑willful, talk to counsel about options like amended returns or other procedures appropriate for non‑willful errors. The IRS discusses alternatives on the VDP page.