IRS Announces “Good Faith” Extension of Voluntary Disclosure Deadline

The IRS said on Thursday 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 Aug. 31, but are unable to submit a complete package, the Service said in updated questions and answers (Q&A’s) on the OVDI. (For previous JofA coverage, see “ IRS Announces Second Offshore Voluntary Disclosure Program .”)


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.


Updates were also made to Q&A’s on case resolution (Q&A’s 51.1, 51.2, 51.3); answers 32 and 35 on calculating the offshore penalty; and answers 51 and 52 on case resolution.


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