You can still apply to the IRS voluntary disclosure program even if you missed the September 9, 2011 OVDI deadline.  The OVDI pre-determined penalty rules will no longer automatically apply, but protection from criminal prosecution may still be obtained.

You may have read that the IRS is continually working with foreign banks and other financial institutions to obtain information on U.S. persons with funds in offshore financial accounts.  If you are still considering the voluntary disclosure program, it is important to move quickly.  Once the IRS has information that you have an unreported foreign financial account, you may no longer be permitted to participate in the voluntary disclosure program.

If you are hesitating to sign up for voluntary disclosure because of the penalties, it is important to consult with a tax attorney, because the computations are complex, and the penalties could be lower than you expect.

Please telephone us at (212) 759-0097 to set a meeting to discuss your options, or at our website at http://www.mbrlawfirm.com/