Thursday, September 17, 2009

The IRS’s highly publicized voluntary offshore disclosure initiative is set to end on September 23, 2009. In exchange for full disclosure of offshore accounts by taxpayers not under investigation, the IRS generally will agree not to seek criminal prosecution for tax evasion. Taxpayers must pay back taxes, plus interest and penalties, for six years. September 23 is also the deadline for some taxpayers to file a delinquent Form TD F 90-22, Report of Foreign bank and Financial Accounts (FBAR) without penalty.

"The only way to resolve these tax compliance problems with a high degree of certainty is to enroll in the voluntary disclosure program, and taxpayers have a limited time to get into the program before the doors close," Daniel Gottfried, a member of the Corporate and Business Law Department, Day Pitney, LLP, Hartford, Conn., told CCH.

Application. The IRS has instructed taxpayers to contact the nearest Special Agent in Charge, IRS Criminal Investigation, or submit a letter requesting participation in the initiative. The IRS has posted a streamlined application on its web site (,,id=205909,00.html).

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