The IRS has extended to 10/15/09 the deadline for joining its special initiative voluntary disclosure practice with respect to foreign bank accounts and entities. The announcement is here. The IRS updated its FAQs here with this extension (see opening unnumbered paragraphs).
I think this will be win-win for the IRS. There will still be plenty of taxpayers who choose not to try to enter the program or, if they try, will be disqualified. The initiative and this extension will thus flush out a lot of tax dollars with relatively little IRS audit / criminal investigatiove costs, and much of the dollars might have otherwise escaped the IRS's radar screen or willingness to pursue.
I think it will also be win-win for the taxpayers involved. The taxpayers entering the practice and not disqualified will receive a pass on criminal prosecution and will pay taxes, penalties and interest that are far less than might otherwise be the case.
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