“Last & Best” 2011 Offshore Voluntary Disclosure Initiative
On February 8, 2011, the Internal Revenue Service announced the “last and best” voluntary disclosure program for those with offshore accounts. The official name of the program is the “2011 Offshore Voluntary Disclosure Initiative” (OVDI). This new program is scheduled to run through August 31, 2011.
The last official voluntary disclosure program was offered in 2009, and the previous program before that was in 2003. The IRS has stepped up its efforts to enforce the tax code on those hiding money overseas and on February 8, 2011, Douglas H. Shulman, IRS Commissioner stated:
this new disclosure initiative is the last, best chance for people to get back into the system. Tax secrecy continues to erode… We are not letting up on international tax issues, and more is in the works. For those hiding cash or assets offshore, the time to come in is now. The risk of being caught will only increase …
Why is the IRS having another voluntary disclosure program?
The 2009 program proved to be an effective tool for getting people to come forward. Under the 2009 offshore voluntary disclosure program there were about 15,000 voluntary disclosures, including accounts from banks in more than 60 countries. Since that time, an additional 3,000 taxpayers have come forward to the IRS with bank accounts from around the world. The IRS has amassed a lot of information from the taxpayers who have come forward, banks and financial institutions, as well as, IRS criminal prosecutions. This program will offer additional incentives for disclosure to the IRS and, therefore, increase its ability to identify people with offshore bank accounts and investments.
Is this the same thing the IRS just offered in 2009?
No. This program has different requirements and specific potential advantages and disadvantages which you should carefully consider under the advice and counsel of a tax attorney who is experienced in this area of representation. Furthermore, is a hard deadline of August 31, 2011, to comply with the program requirements – a major difference between this initiative and the previous amnesty program. The previous amnesty program provided that all once had to do was start the application by the due date, with this 2011 initiative, you must finish program requirements by August 31, 2011.
Seeking the protection of this voluntary disclosure program is a serious decision and should be done properly. We at the law firm of Stephen Moskowitz, LLP have many years of substantial experience with the voluntary disclosure program, international tax issues, and related matters in advice, execution, and legal defense. Let us explain to you how this program could relate to you, whether you have an unreported foreign bank account, or if you could be accused of other tax wrongdoing. Call 415-394-7200 or email Steve Moskowitz for your complimentary attorney-client privileged consultation with the senior partner of our tax law firm.