The Internal Revenue Service has announced a new initiative designed to encourage taxpayers with undisclosed offshore bank and investment accounts to make voluntary disclosure of those accounts and to bring themselves into compliance with U.S. tax laws. This new initiative — called the 2011 Offshore Voluntary Disclosure Initiative — is the second such initiative and follows the 2009 Offshore Voluntary Disclosure Program.
The overall structure of the 2011 initiative is similar to the 2009 program but with a slightly higher penalty structure, so that taxpayers who did not participate in the 2009 program will not be rewarded for having failed to participate in that program. However, the 2011 initiative does allow for a reduced penalty rate in certain situations, including those involving smaller offshore accounts.
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