2012 Offshore Voluntary Disclosure Program, here.
This is the key web site with links to the related web sites (including FAQs and various documents to submit.Offshore Voluntary Disclosure Program Frequently Asked Questions and Answers, here.
Offshore Voluntary Disclosure Program Submission Requirements, here.
Options Available to Help Taxpayers With Offshore Interests, here.
1. From FAQ 21, regarding how taxpayers may become ineligible for OVDP 2012.
Second, the IRS may announce that certain taxpayer groups that have or had accounts at specific financial instructions will be ineligible due to U.S. government actions in connection with the specific financial institution. Such announcements will provide notice of the prospective date upon which eligibility for specific taxpayer groups will be posted to the 2012 Offshore Voluntary Disclosure Program page.2. FAQ 24 requires the OVDL (the form letter to IRS CI after preclearance is received) and an attachment for each foreign financial account. The attachment requires a lot of information about how the particular foreign account operated, including identifying enablers and their roles.
3. FAQ 9 describes the disclosure period (the period for which amended returns and delinquent or amended FBARs will be required). I am not sure I understand the logic of the calculation of the period, but in broad strokes, it is to calculate the period as the preceding 8 calendar years for which the latest year filing date (including extensions) has not already passed. Thus, the example: "for taxpayers who submit a voluntary disclosure prior to April 15, 2012 (or other 2011 due date under extension), the disclosure must include each of the years 2003 through 2010 in which they have undisclosed foreign accounts and/or undisclosed foreign entities." I assume, therefore, that for calendar year taxpayers filing for OVDP after 4/15/12 (without extensions) and after 10/15/12 (with extensions), the eight year period starts for the year 2004 at the earliest with seriatim years dropping off after each due date (original or with extensions) expires. And, if the taxpayer became compliant in any of those eight years, those years will not be included in the 8 year disclosure period (i.e., the 8 year disclosure period is reduced by the compliant years). [I am not sure that this latter rule will have a major effect in most cases unless the taxpayer increased the amounts in foreign banks or foreign assets during the compliant years; perhaps readers can comment.]