Posted by: Taxlitigator | June 18, 2011

Making a Voluntary Disclosure Under the 2011 OVDI

How to Make a Voluntary Disclosure Under the 2011 OVDI 

The 2011 Offshore Voluntary Disclosure Initiative (OVDI) is offered to those taxpayers having interests in previously undisclosed interests in offshore financial accounts or assets. Frequently Asked Questions (FAQs) are available at  http://www.irs.gov/businesses/international/article/0,,id=235699,00.html

Pre-Clearance:

Taxpayers or representatives may fax to the IRS Criminal Investigation Lead Development Center at (215) 861-3050 the taxpayers’ name, date of birth, social security number and address (if the taxpayer is represented by a tax professional, an executed power of attorney must be included).

IRS Criminal Investigation will then notify taxpayers or their representatives via fax whether or not they have been cleared to make a voluntary disclosure using the Offshore Voluntary Disclosures Letter. Taxpayers or representatives with questions regarding the pre-clearance can call (215) 861-3759 or contact their nearest Criminal Investigation Office.

Note: Pre-clearance does not guarantee a taxpayer acceptance into the 2011 OVDI. Taxpayers must truthfully, timely, and completely comply with all provisions of the 2011 Offshore Voluntary Disclosures Initiative.

Offshore Voluntary Disclosure Letter

If the taxpayer chooses to submit a pre-clearance request, after the taxpayer receives a pre-clearance notification, the taxpayer will have 30 days from receipt of the fax notification to complete the Offshore Voluntary Disclosures Letter (available at  http://www.irs.gov/pub/irs-utl/2011-ovdi-irs-ci-letter-01-31-2011.doc ). If the taxpayer chooses to bypass the pre-clearance process, the taxpayer must mail the Offshore Voluntary Disclosures Letter to the following address:

Internal Revenue Service

Criminal Investigation

ATTN: Offshore Voluntary Disclosure Coordinator

Philadelphia Lead Development Center

600 Arch Street, Room 6406

Philadelphia, PA 19106

The IRS will review the offshore Voluntary Disclosures Letters and notify the taxpayer or representative by mail whether the voluntary disclosure has been preliminarily accepted or declined.

Complete Voluntary Disclosure Package

Once the voluntary disclosure has been preliminarily accepted, the taxpayer should send the full voluntary disclosure package no later than August 31, 2011 to:

Internal Revenue Service

3651 S. I H 35 Stop 4301 AUSC

Austin, TX 78741

ATTN: 2011 Offshore Voluntary Disclosure Initiative

Information regarding the complete OVDI package submission requirements is available at   http://www.irs.gov/businesses/international/article/0,,id=235690,00.html

Opt Out Procedure

Taxpayers may request to opt out of the civil settlement structure of the 2009 Offshore Voluntary Disclosure Program or 2011 Offshore Voluntary Disclosure Initiative. For specific information on the opt out process, see questions 51.1 through 51.3 under the 2011 OVDI Frequently Asked Questions and Answers.

Taxpayers wishing to make a domestic voluntary disclosure that is not covered under the OVDI should contact their local IRS Criminal Investigation (CI) office to speak with a criminal investigator.


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