Home > International, IRS > Hurricane Irene Extends OVDI Deadline to September 9, 2011

Hurricane Irene Extends OVDI Deadline to September 9, 2011

The eye of Hurricane Irene is approaching New York City. At approximately 7:00PM (just under an hour from the writing of this post), the strong bands of rain are expected to arrive, and continue throughout the night into tomorrow.

Fortunately, I live in a “no zone.” This means that, according to folks at the Mayor’s office who put this map together, I face a strong threat of flooding only if the hurricane becomes a category 3 or 4, which appears very unlikely. Unfortunately a close colleague of mine lives in Zone A. Residents of Zone A were required to evacuate their homes by 5:00PM today. As unhappy as he was with having to take his four kids elsewhere, it’s better to be safe than sorry.

Representing taxpayers who are participating in the 2011 Offshore Voluntary Disclosure Initiative, I was concerned with some clients not timely meeting the August 31 deadline if required documents were not in transit to the IRS before I left the office yesterday. I can’t assume that roads will be drivable on Monday or that the NYC subway system will resume operations by then. So I decided to work late and wrap up OVDI matters, in order to be safe than sorry.

So, it turns out I’m not the only one concerned about this. The IRS is too. Yesterday, the IRS announced that the due date for offshore voluntary disclosure requests has been extended to September 9, 2011, due to Hurricane Irene.

The cynic interprets this announcement as a last-ditch effort to publicize the program. Although that motive may be at play here, the bottom line is that taxpayers who waited until the last opportunity to participate in the program were just given some more time, courtesy of the IRS. And taxpayers with undisclosed foreign accounts should strongly consider doing so.

Categories: International, IRS Tags: ,
  1. NA
    September 4th, 2011 at 18:00 | #1

    I have maintained bank account in India for the last few years but the aggregate of total deposits in any year has been lot less that $10,000 (varies from $200 to $1500). I have been mainly using this account during my travel back to India for a limited period. Even though there has been interest income, it has been very small and it even does not add up to $50 over these years. I did not report this interest income as it was so little and I did not have proper bank statements during the tax filing period here. I am aware about Sept. 9th deadline and I am trying to figure out if I should mail Offshore Voluntary Disclosure Letter to IRS Criminal Investigation department. I would appreciate if you have any thoughts.

    Thank you,


    • September 5th, 2011 at 14:37 | #2

      The 2011 OVDI program is for taxpayers who (I) were required to disclose foreign financial accounts during the periods in question but did not, AND (II) earned income on the accounts but did not report it to the Internal Revenue Service.

      The FBAR filing threshold is not dependent on deposits, but on the total maximum balances of all accounts during the year in question.

      • Anonymous
        September 5th, 2011 at 16:24 | #3

        Looks like I was not required to disclose (form TD F 90-22.1) foreign financial account as the total aggregate of max. balance during any year was less than $10,000.

        However, I should have reported interest income, even though it was few dollars during a year.

        I guess I should go ahead and disclose and pay whatever reasonable penalty IRS might ask me to pay?

        Many Thanks!

  2. LW
    September 6th, 2011 at 14:50 | #4

    My husband and I file our income taxes jointly. The total of my balance with couple of overseas bank accounts is less than $10,000 during any year in the past and hence I guess there was no need for me to disclose my overseas account information. However, my husband opened a fixed deposit account late in 2010 and the balance it is little above $10,000. None of these overseas accounts are held by us jointly.

    We have already sent Offshore Voluntary Disclosure letter for my husband to IRS and have sent another letter seeking 90 days extension to complete the paper work.

    I am assuming that even though we file tax jointly and since our overseas accounts are separate, only the spouse that qualifies for Offshore Voluntary Disclosure need to do so.

    We have done whatever reading we could and did not find any clear information related to this situation. I am wondering if I need to also send out Offshore Voluntary Disclosure letter and seek for an extension to complete the paper work.

    Any information you may have regarding this would be great.


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