New Year’s Resolution: Disclosing Your Foreign Bank Account?


The IRS reported in November of 2009 that over 14,000 taxpayers entered the special voluntary disclosure program for offshore accounts. That program deadline expired on October 15, 2009. However, despite the expiration of this special program, taxpayers continue to avail themselves of the IRS’s longstanding general voluntary disclosure program. The IRS’s general program is described in the Internal Revenue Manual section IRM See,,id=104361,00.html. We understand that the IRS received numerous disclosure filings under the general program subsequent to the expiration of the special program deadline.

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