New Offshore Voluntary Disclosure Program Coming Soon


The IRS today reiterated that it will soon announce a second Voluntary Offshore Compliance Initiative (OVCI). The OVCI will likely be more rigorous than the program that ended October 15, 2009. That program required a taxpayer to file six years of Foreign Bank Account Reports (FBAR’s) and file amended tax returns to report previously unreported income and pay the tax, interest and civil penalty. The OVCI also imposed an FBAR penalty of 20% of the highest single year account balance, rather than 20% per year. The maximum statutory penalties according to the IRS was an aggregate 240% if the taxpayer did not take advantage of the OVCI and were to subsequently be discoverd. The 240% was exclusive of criminal penalties.

The new initiative follows the filing of almost 17,000 Voluntary disclosures under the first OVCI. Most of the 17000 were from UBS account holders, although not all.

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