Legal Alert: IRS Announces a Third Offshore Voluntary Disclosure Program
The IRS Announces a Third Offshore Voluntary Disclosure Program
by Carlene Y. Lowry and William A. Kastin
We previously reported on two offshore voluntary disclosure programs initiated by the IRS to bring persons back into compliance who failed to report an interest in, or signature authority over, one or more offshore financial accounts. These reporting requirements are generally referred to as the “FBAR” reporting requirements. The first program ran from March 23, 2009 thru October 15, 2009 (2009 OVDP), the second program ran from February 8, 2011 thru September 9, 2011, with an extension for certain supplemental information to be provided by December 9, 2011 (2011 OVDI).