The IRS has announced a second offshore voluntary disclosure initiative intended to bring more taxpayers into compliance with the tax rules and bring offshore money back into the U.S. tax system. The 2011 Voluntary Disclosure Program changes and clarifies some of the rules of the previous disclosure initiative, provides guidance to taxpayers and IRS examiners about how the guidelines are to be applied to the additional disclosures and presents a further disclosure opportunity for United States taxpayers with undisclosed foreign accounts.

On February 8, 2011, the Internal Revenue Service (IRS) announced a second offshore voluntary disclosure initiative (hereinafter, the “2011 Voluntary Disclosure Program”) intended to bring more taxpayers into compliance with the tax rules and bring offshore money back into the U.S. tax system. The first offshore voluntary disclosure initiative was announced in 2009 (hereinafter, the “2009 Voluntary Disclosure Program”) and ended on October 15, 2009. The 2009 Voluntary Disclosure Program was applicable for the 2003 through 2008 calendar years and, based on government announcements, resulted in approximately 15,000 disclosures. Since October 15, 2009, the IRS has received more than 3,000 additional disclosures. The 2011 Voluntary Disclosure Program, which changes and clarifies some of the rules in the 2009 Voluntary Disclosure Program, is available through August 31, 2011, and is applicable for the 2003 through 2010 calendar years. It provides guidance to taxpayers and IRS examiners about how the guidelines are to be applied to the 3,000 additional disclosures and presents a further disclosure opportunity for United States taxpayers with undisclosed foreign accounts.