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ARTICLE · 08 OCTOBER 2012

Do Not Get Out Of IRS’s Tax Amnesty Programs Without Knowing The Facts

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In light of the IRS’s new streamlined procedure for bringing the delinquent tax returns of US persons current, many taxpayers who are currently in the 2009 Offshore Voluntary Disclosure Program (OVDP) or 2011 Offshore Voluntary Disclosure Initiative (OVDI) are considering opting out of these amnesty programs in the hope of filing under the new procedure.

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In light of the IRS's new streamlined procedure for bringing the delinquent tax returns of US persons current, many taxpayers who are currently in the 2009 Offshore Voluntary Disclosure Program (OVDP) or 2011 Offshore Voluntary Disclosure Initiative (OVDI) are considering opting out of these amnesty programs in the hope of filing under the new procedure.  Recently we published an extensive analysis of the new streamlined procedure, which you may find by clicking here.

While opting out of these amnesty programs may result in a reduction of penalties that may otherwise be assessed, the taxpayer needs to carefully weigh the numerous consequences before doing so, not the least of which is the fact that opting out is irrevocable and cannot be undone. Responsible tax professionals will discuss the consequences of opting out with the client before making such a recommendation.  Professionals who do not fully analyze all of the client's facts and current IRS positions risk

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