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The IRS has given U.S. taxpayers participating in the IRS Offshore Settlement Initiative Program (“the Initiative”) until January 15, 2010 to provide additional information to the IRS concerning offshore accounts.  Thus, U.S. taxpayers with accounts in foreign banks have just over 2 weeks to make a complete voluntary disclosure of their accounts to the IRS or risk facing increased monetary penalties – which can exceed the value of the account – and potential criminal prosecution.  Taxpayers who failed to enter the Initiative may still potentially take advantage of the reduced penalty framework by filing before January 15, 2010. 

U.S. taxpayers with accounts in foreign banks have only 1 week left (January 15, 2010) to make a complete voluntary disclosure of their accounts to the IRS or risk facing increased monetary penalties.