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ARTICLE · 14 MARCH 2011

An Update On Offshore IRS Voluntary Disclosure

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In the wake of the UBS litigation seeking the identity of U.S, taxpayers with accounts in Switzerland, the Internal Revenue Service offered a special new voluntary disclosure program for U.S. taxpayers with undisclosed offshore financial accounts and unreported offshore income.

United KingdomTax
Paul Behling
Paul Behling
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Overseas accounts now trigger new reporting requirements.

In the wake of the UBS litigation seeking the identity of U.S, taxpayers with accounts in Switzerland, the Internal Revenue Service offered a special new voluntary disclosure program for U.S. taxpayers with undisclosed offshore financial accounts and unreported offshore income. Approximately 15,000 taxpayers came forward under a special IRS program that ended Oct. 15, 2009, and many others applied after the deadline with the expectation of another offshore program. The new offshore disclosure program was announced by the IRS on Feb. 8, 2011.

Voluntary Disclosure

For those of us who have handled voluntary disclosures prior to the 2009 special offshore program and continue to process disclosures, the 2009 offshore disclosure process was an arduous, expensive and time consuming process. The IRS has since worked with members of the bar to find ways to streamline the process; however, the service has become

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