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After successfully collecting over $5 billion from offshore
voluntary disclosure programs (OVDP) in 2009 and 2011, the IRS
extended its OVDP indefinitely. On June 26, 2012 the IRS issued new
frequently asked questions and answers (FAQ) about the current
program. The FAQ are careful to point out that the OVDP could be
amended or terminated at any time.
Under the current OVDP, the penalty structure remains
essentially the same as the 2011 program except for taxpayers in
the highest penalty category. Individuals whose offshore accounts
or assets did not exceed $75,000 in any calendar year covered by
the new OVDP may qualify for a 12.5% penalty. SeeFAQ 53. Certain taxpayers with foreign
residency or minimal contact with a foreign account may qualify for
a special 5% penalty. SeeFAQ 52. Participants must file all original
and amended tax returns and include payment for all back taxes and
interest, as well as accuracy-related penalties or delinquency
penalties. The new FAQ point out that the new Form 8938 must
accompany any required amended or original return for years after
2010.
Along with the new FAQ, the IRS has created new filing
compliance procedures for nonresident U.S. taxpayers who do not
qualify for the OVDP. These procedures will go into effect
September 1, 2012. There are also special rules for holders of
certain Canadian retirement accounts that did not make timely
treaty elections. The FAQ can be found at http://www.irs.gov/businesses/small/international/article/0,,id=256774,00.html.
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