On February 8, 2011, the IRS unveiled the 2011 Offshore Voluntary Disclosure Initiative (“OVDI”), pursuant to which taxpayers may come forward, through August 31, 2011, to report previously undisclosed foreign accounts, assets, and income.

The OVDI follows the 2009 Offshore Voluntary Disclosure Initiative (“OVDP”), which was effective from March through October of 2009 and elicited disclosures from about 15,000 taxpayers. However, the overall penalty structure for OVDI is higher than the penalty structure that was in place for OVDP.