If a taxpayer makes all the requisite disclosures and receives the preclearance then they must make their disclosure. Note these guidelines are subject to change. Consult the IRS’s website for the most recent OVDI procedures.  Under the IRS’s guidelines:
Internal Revenue Service
Voluntary Disclosure Coordinator
2970 Market Street
Philadelphia, PA 19104
OVDI Criminal Investigation will review the Offshore Voluntary Disclosure Letter and notify taxpayers or representatives by mail or facsimile whether their offshore voluntary disclosures have been preliminarily accepted as timely or declined. Criminal Investigation intends to complete its work within 45 days of receipt of a complete Offshore Voluntary Disclosure Letter.
Once a taxpayer’s disclosure has been preliminarily accepted by CI as timely, the taxpayer must complete the submission and cooperate with the civil examiner in the resolution of the civil liability before the disclosure is considered complete.
Assuming there is preliminary acceptance into ODVI, a letter will be received from the Criminal Investigative unit. The letter will instruct the taxpayer or his representative to submit the full voluntary disclosure submission to the Austin Campus within 90 days of the date of the timeliness determination. The taxpayer must provide the following:
You may also be contacted by an OVDI examiner for specific additional information to process your voluntary disclosure. The examiner will certify that your voluntary disclosure is correct, accurate, and complete by reviewing your records along with your amended or delinquent income tax returns. The examiner will also verify the tax, interest, and civil penalties you owe.
A complete submission is required for acceptance into the OVDI program. Taxpayers may submit voluminous documents not requiring original taxpayer signatures (e.g., bank statements, entity organization documents, etc.) on a compact disc (CD) or a USB removable storage device (flash drive). Normally, other than an examination for completeness, no examination will be conducted with respect to the disclosure; however, the IRS does reserve this right. The OVDI operates on a first come, first serve basis. If you are seriously contemplating entering into this program, you should begin to have the amended tax returns prepared and gather the necessary documents at the time you file for preclearance.
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