IRS reopens offshore OVDI program for indefinite time period

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The IRS reopened their successful Offshore Voluntary Disclosure Initiative (OVDI) for nonfilers of both U.S. tax returns and Foreign Bank Account Reports (FBARs) on January 9, 2012 with News Release IR-2012-5. This announcement provided further guidance to both taxpayers who have just become aware of their filing obligations or did not participate in the 2009 and 2011 OVDI programs. Practitioners who advise clients with a wide variety of facts and circumstances can now offer the options set forth in IR-2012-5 along with the alternatives set forth in FS-2011-13 if a delinquent return filer owes no tax.

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