Last week the IRS released a memorandum with new procedures for an "Updated Voluntary Disclosure Practice" impacting…
IRS Announces “Good Faith” 90 Day Extension of Voluntary Disclosure Deadline
The IRS said last week that it is making available to taxpayers a 90-day deadline extension to participate in the 2011 offshore voluntary disclosure initiative (OVDI). The extension would be available to taxpayers who have made a good faith attempt to fully comply by August 31, 2011, but are unable to submit a complete package, the IRS said in updated questions and answers (Q&A’s) on the OVDI.
According to Q&A 25.1, the good faith attempt to fully comply must include the properly completed and signed agreements to extend the period of time to assess tax (including tax penalties) and to assess penalties for failure to file Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR). Requests for up to a 90-day extension must include a statement of those items that are missing, the reasons they are not included, and the steps taken to secure them.
Patel Law Offices is a law firm dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems. Our firm assists (and defends) clients and their advisors to legally disclose (and legitimze) foreign accounts.