I. OVERVIEW
A. Description of the program
On February 8, 2011 the Internal Revenue Service (IRS) unveiled
its latest initiative to encourage taxpayers to report undisclosed
foreign accounts and assets and unreported income from such
accounts and assets. The program, titled the 2011 Offshore
Voluntary Disclosure Initiative (2011 OVDI), offers eligible
taxpayers several incentives for reporting offshore assets
maintained during the 2003 through 2010 tax years covered by the
program. The program enables delinquent taxpayers to become
compliant, avoid compounded civil penalties, minimize the risk of
criminal prosecution, and calculate, with a relative degree of
certainty, the total cost of resolving offshore tax issues. In
exchange, participants in the initiative must, among other things,
file all original or amended tax returns, update all offshore
information returns, agree to extend the statute of limitations on
assessment, remit all back taxes, along with interest
