A Second Bite At The Apple

Private Wealth
In this article, Tom Zehnle and Steve Dixon discuss the 2011 Offshore Voluntary Disclosure Initiative, announced by the IRS on February 8. The initiative follows the fairly successful 2009 Offshore Voluntary Disclosure Program that officially closed in October 2009 after accepting almost 15,000 voluntary disclosures. Like the earlier program, the current initiative is meant to provide "consistency and predictability to taxpayers"—provided they fulfill the program’s requirements on or before August 31. Like its predecessor, the 2011 OVDI couples ordinary voluntary disclosure—which dramatically minimize the chance that a taxpayer will face criminal prosecution for tax violations—with the promise of consistency and leniency on the civil side by "defining the number of tax years covered and setting the civil penalties that will apply."
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