October 9, 2011 was the last day to enroll in the Second Supplemental Offshore Voluntary Disclosure Initiative (OVDI) offered by the IRS. The IRS allowed taxpayers who enrolled by filing a voluntary disclosure letter by October 9, 2011 to have up to December 9 to complete the submission of required documents. Between the 2009 Offshore Voluntary Disclosure Compliance Program (OVDP) and the 2011 OVDI more than 33,000 taxpayers made submissions to the IRS. But what happens next? What is the process for the those taxpayers who have not enrolled in either program? This is a question that the IRS needs to answer soon.

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