Penalty relief for delinquent FBARs and international information returns

June 2012


In January 2012, the IRS announced a third, now permanent, 2012 Offshore Voluntary Disclosure Program (2012 OVDP).  On June 26, 2012, the IRS released detailed guidance for participating in the 2012 OVDP, including Frequently Asked Questions (“FAQs”).  While the 2012 OVDP focuses on taxpayers who owe tax, similar to the two prior temporary offshore voluntary compliance intiatives, the 2012 OVDP FAQs also include penalty relief for delinquent TD F 90-22.1, Report of Foreign Bank and Financial Accounts (“FBARs”) and international information returns.  More information about this penalty relief is provided below.  For details on the January announcement of the 2012 OVDP, see IRS Hot Topics: IRS reopens offshore OVDI program for indefinite time period.

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Pam Olson
US Deputy Tax Leader & Washington National Tax Services Leader
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