On August 26, 2011, the Internal Revenue Service extended the deadline for participation in the 2011 Offshore Voluntary Disclosure Initiative to September 9, 2011.
My communications with the IRS during the past week indicate that the Service will be much more ridged during this 2011 Initiative than it was during the 2009 Initiative. The civil review of the 2011 disclosures has been consolidated in the Austin Office. During the 2009 Initiative, review of the disclosures was dispersed among offices all across the United States. Apparently this decentralization caused issues, among which were very liberal extensions of time for the tax payers to come into compliance with the program. My understanding is that such leniency is unlikely throughout the 2011 Initiative.
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