IRS Extends Deadline for Offshore - What Must Be Filed?

The IRS stated on August 26 and further clarified on August 29 that due to the potential impact of Hurricane Irene it has extended the due date for its 2011 Offshore Voluntary Disclosure Initiative (OVDI) requests and several other required informational returns from August 31, 2011 until September 9, 2011.

For those taxpayers who have not yet submitted their request and any documents, the IRS has indicated that the following actions are necessary by September 9, 2011:

• Identifying information must be submitted to the Criminal Investigation office. This includes name, address, date of birth, and social security number and as much of the other information requested in the Offshore Voluntary Disclosures Letter as possible. This information must be sent to:
  
  Offshore Voluntary Disclosure Coordinator
  600 Arch Street, Room 6404
  Philadelphia, PA 19106
• Send a request for a 90-day extension for submitting the complete voluntary disclosure package of information to the Austin campus. This request must be sent to:
  
  Internal Revenue Service
  3651 S. I H 35 Stop 4301 AUSC
  Austin, TX 78741
  ATTN: 2011 Offshore Voluntary Disclosure Initiative

The IRS's 2011 OVDI established a framework of penalties for taxpayers who become fully tax compliant for unreported offshore income, accounts, civil law foundations, trusts or entities for years between 2003 and 2010.

The IRS also extended the deadline for filing delinquent Reports on Foreign Bank and Financial Accounts (FBAR) that were due for calendar years prior to 2010 until September 9, 2011.

In addition, the IRS will not impose a penalty for the failure to file the information returns Form 5471 for controlled foreign corporations or Form 3520 for foreign trusts if there are no underreported tax liabilities and the information returns are filed by September 9, 2011.