United States - FBAR and tax return non filers in the post IRS OVDI environment - What are the options now?

Global Watch ()

The Internal Revenue Service (IRS) ended their 2011 Offshore Voluntary Disclosure Initiative (OVDI) for non filers of both U.S. tax returns and Foreign Bank Account Reports (FBARs) on December 9, 2011. The IRS issued an announcement on December 13, 2011 (Fact Sheet (FS) -2011-13) that summarizes the filing requirements and potential penalties for delinquent tax returns and FBARs. FS-2011-13 provided welcome guidance for many dual citizens and green card holders living outside the U.S., who owed no tax but had FBARs due, had reasonable cause, and who wished to come into tax return and FBAR compliance. Questions remain, however, for the same population that owes U.S. federal tax.