Tax professionals or individuals who want to make a voluntary disclosure not covered by the 2011 Offshore Voluntary Disclosure Initiative, may contact an IRS criminal investigator at the numbers below.I speculate that
1. As in the two programs (OVDP 2009 and OVDI 2011) the IRS will discourage quiet disclosures of foreign financial institution accounts. Will the IRS and DOJ Tax will pick off one or two or more where the quiet is not quite up to snuff and prosecute? (I can't define the up to snuff standard; it is like pornography -- you will know it when you see it and good practitioners will prevent their clients from submitting not up to snuff quiet disclosures.)
2. Taxpayers making the disclosures will be required to produce the types of packages required under the formal programs, in essence doing all the work for the IRS.
3. The amount of the civil penalties will be higher than in OVDI 2011, although it is uncertain whether that will be achieved by an informal program rate (take it or leave it and go through audit) or on a case by case basis through an audit.