On 2/8/11, the IRS announced the 2011 Offshore Voluntary Disclosure Initiative (2011 OVDI). This is the second opportunity the IRS has given to all U.S. taxpayers with undisclosed offshore accounts, to come clean, avoid substantial civil penalties, and basically eliminate the risk of criminal prosecution. The 2011 OVDI applies to individuals as well as corporations, partnerships, and trusts. Just like any other voluntary disclosure, the new 2011 OVDI is based on Internal Revenue Manual (IRM) section 9.5.11.9.