participate in the 2011 OVDI taxpayers must come forward and complete all filing requirements on or before August 31, 2011. A disclosure is made by a taxpayer by submitting a letter signed under penalties of perjury that includes complete identifying information of the taxpayer and details of the foreign accounts/assets, such as the institutions where they are held, the years the accounts were open, the balances in the account and the income generated in the accounts, the identification of all people or entities affiliated with the account, the contacts at the bank and a description of any face to face meetings. Upon submission of this letter, the IRS Criminal Division will check to see if the taxpayer has made a timely disclosure and is eligible to make aForeign Gifts, among others).

The announcement of the 2011 OVDI included statements from the IRS that those taxpayers that do not come forward will bear the risk of criminal prosecution and higher penalties if they are detected by the IRS. The IRS has expanded its focus on foreign banks from Europe to banks in Asia, the Middle East and Central America and has obtained information about the banks’ U.S. accountholders from treaty requests, summonses and whistleblowers. The IRS also will begin to receive additional information about foreign accounts when the new Foreign Account Tax Compliance Act and the Statement of Foreign Financial Assets Form become effective. As the IRS continues to erode bank secrecy, the Commissioner of the IRS has pointed out that the 2011 OVDI “is the last,