On June 2, 2011, the IRS provided additional guidance regarding its 2011 offshore voluntary disclosure initiative (OVDI) in the form of revised frequently asked questions (FAQs).

The new guidance:

• allows taxpayers to request up to a 90-day extension to submit all necessary documentation under the program;

• provides reduced FBAR penalties for certain U.S. taxpayers who reside in foreign countries and have been compliant with such countries’ tax obligations; and

• provides examples and procedures for taxpayers to opt out of the civil settlement structure of the OVDI program.