Widespread speculation has existed within the US tax community for a number of months about a new IRS “amnesty” program focused on US taxpayers with non-disclosed assets held outside of the US. Today, IRS formally announced the program entitled the 2011 Offshore Voluntary Disclosure Initiative (the “2011 OVDI”).

Though IRS has stressed that the 2011 OVDI is no more generous than the prior IRS amnesty program that expired on 15 October 2009, the penalty provisions of the new program may, in fact, provide better results for some taxpayers. US citizens, US residents and US green card holders who considered coming forward under the 2009 amnesty program but declined to do so should reconsider their positions in light of the new 2011 OVDI and the success IRS has experienced in piercing the veil of bank secrecy in many jurisdictions throughout the world since 15 October 2009 – a trend that will only intensify in the years to come.