The IRS has announced the 2012 Offshore Voluntary Disclosure Program for Foreign Accounts, Foreign Bank Accounts and FBAR filings. The 2012 follows the pattern set by the 2009 IRS Offshore Voluntary Disclosure Program and the 2011 Foreign Bank Account Voluntary Disclosure Programs. The voluntary disclosure programs include reduction of penalties related to foreign accounts and assets but each new program has featured less of a reduction. The 2012 OVDP uniquely does not have a deadline, but the IRS has reserved the right to increase penalties and change any other terms of the program at any time. Since 2009 the trend has been for terms to become less favorable. The penalties have increased with each new offshore disclosure program, though they remain far less than what a taxpayer would face without the program. Therefore it behooves the taxpayer to enter the program as quickly as possible so that they receive the most favorable terms.
For more information on the 2012 Offshore Voluntary Disclosure Program or for more tax related legal concerns, contact Horowitz & Weinstein.