The IRS reopened the Offshore Voluntary Disclosure Program, which closed on 9/9/11. The third offshore program will be open indefinitely, until otherwise announced, and will provide the same penalty structure except for taxpayers in the highest penalty category. Participants will have to pay a penalty of 27.5% of the highest aggregate balance in foreign bank accounts/entities or value of foreign assets during the eight full tax years prior to the disclosure, which is up from 25% in the 2011 program. However, some will be eligible for a 5% or 12.5% penalty rate. Those who feel that the penalty is disproportionate may opt instead to be examined. As before, participants will have to file all original and amended tax returns and include payment of back-taxes and interest for up to eight years, as well as accuracy-related and/or delinquency penalties. News Release IR-2012-5 .
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