For those taxpayers who are still considering whether to apply for amnesty under the 2011 Offshore Voluntary Disclosure Initiative (OVDI) or who have not yet completed the program, you should be aware that the August 31st deadline is not only to file the initial application to the program but also to submit the complete civil package that includes the amended income tax returns, delinquent FBAR’s (Form TD F 90.22-1), bank statements, etc.
Recognizing that many people would have trouble meeting the deadline, in June 2011, the IRS announced an extension for compliance with the OVDI Program. The extension must be in writing by Aug 31, the taxpayer must have made a “good faith” attempt to comply by the deadline, and certain detailed information must be included.
It is important to note that the extension offered is not an automatic extension. As such, absent an approved IRS extension for the OVDI program, your rights may be affected.
The decision as to whether an individual should participate in the OVDI is difficult; seek the assistance of a qualified attorney immediately.