January 24, 2011 - Phil Hodgen

If by “entice” you mean “submit and be assimilated” then yes

We know it is coming.  A new amnesty.

(Aside.  The IRS people aren’t supposed to use the word “amnesty” in describing the Offshore Voluntary Disclosure Program.  Just like they’re not allowed to use the words “tax protestor.”)

In the Jan. 24, 2011 edition of Tax Notes Today, 2011 TNT 15-1, there is a report from the ABA Tax Section meeting in Florida.

Steven Miller, IRS deputy commissioner for services and enforcement, gave what are called “wide-ranging luncheon remarks.”  FTFA:

The IRS is close to announcing the details of a follow-up initiative to entice more taxpayers with unreported offshore accounts to voluntarily disclose them to the IRS, Steven Miller, IRS deputy commissioner for services and enforcement, said January 21.

Miller said the new offshore disclosure initiative will not offer terms as generous as those available to taxpayers who participated in the special offshore disclosure program established in 2009, but the structure will be somewhat similar. The IRS intends to use the lessons learned in processing the first batch of offshore cases to guide its new approach, which will include greater centralization, he said.

Significantly, the IRS will allow taxpayers who have made voluntary disclosures since the last special program ended to avail themselves of the terms in the new initiative, Miller said. The IRS’s belief in allowing taxpayers to make voluntary disclosures should be read in the context of the agency’s continued enforcement efforts, he said. The possibility of a second offshore voluntary disclosure program was first raised by IRS Commissioner Douglas Shulman in December.

The IRS received about 15,000 disclosures during the first offshore voluntary compliance program, Miller noted. Since the program expired in October 2009, the agency has received about 3,000 more. Most of the cases have involved previously unpaid taxes, with the average being around $200,000 per case, he said.

Check out that word “entice.”  I don’t know whether it was the reporter’s choice of words or whether Mr. Miller used that word in his remarks. If it was Mr. Miller, then I wonder if he knows the meaning of the word. (YouTube).

UPDATE: Link to NYT article with warnings of the new amnesty. If, by “amnesty,” you mean “maximize revenue for the government.” And yes, in discussions of our cases with IRS personnel they frequently refer to how much money they are collecting on the amnesty cases.

US Real Estate Investments Voluntary Disclosure