New IRS Streamlined Procedure for Offshore Disclosures

On August 31, 2012, the IRS published the new procedures first announced on June 26 regarding offshore voluntary disclosures.  This is essentially a recognition on the part of the IRS that there are certain “no brainer” fact scenarios which qualify for relief from the more formal, expensive, time consuming and intrusive OVDI procedures which is presently bogged down because of a shortage of  IRS  personnel to work the cases.  We first commented on this new streamlined procedure on July 2.  You can access those comments here. There are no surprises in the August 31 announcement. I still believe it is “too little” because it doesn’t go far enough but not “too late” because it shows the IRS recognizes that the oppressive OVDI “one size fits all” approach simply does not make sense when it is applied to people  who represent the unintended collateral damage of the  FBAR penalties when they are applied literally.