The 2011 Offshore Voluntary Disclosure Initiative

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On February 8, 2011, the IRS announced its 2011 Offshore Voluntary Disclosure Initiative, which provides a significant opportunity for taxpayers with undisclosed or under-reported offshore accounts to come forward for what is intended to be a fraction of the cost if the IRS were to discover the accounts on its own. In addition, participation in the program also generally takes criminal prosecution off the table. This article is a summary of the program, its terms, its benefits, and the process taxpayers wishing to participate need to follow.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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