Extension and New Guidance for the Voluntary Disclosure Initiative for Undisclosed Foreign Assets


On June 2, 2011, the IRS provided additional guidance regarding its 2011 offshore voluntary disclosure initiative (OVDI) in the form of revised frequently asked questions (FAQs).

The new guidance:

• allows taxpayers to request up to a 90-day extension to submit all necessary documentation under the program;

• provides reduced FBAR penalties for certain U.S. taxpayers who reside in foreign countries and have been compliant with such countries’ tax obligations; and

• provides examples and procedures for taxpayers to opt out of the civil settlement structure of the OVDI program.

Please see full advisory below for more information.

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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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