The 2011 IRS Offshore Voluntary Disclosure Initiative (“2011 OVDI”) closed on September 9, 2011. The 2011 OVDI gave certain taxpayers the opportunity to come forward and report items of offshore income and file information returns, such as Reports of Foreign Bank and Financial Accounts (“FBARS”) in exchange for a streamlined penalty configuration. Though 2011 OVDI has closed and its New Jersey 2011 counterpart closed September 30, 2011, taxpayers with unreported offshore income issues still have options they can consider if they wish to enter the U.S. taxing system and become compliant. We have been meeting with taxpayers since 2011 OVDI closed advising them on their options. You should consult with a tax advisor as to the facts of your particular situation to craft an approach to your case.