“Effective immediately, expats who agree to disclose their foreign accounts and pay US taxes for the previous three years won’t need to pay any penalties. They’ll owe just back taxes and interest (if any). The IRS even extended an olive branch to resident Americans. They’ll be able to come forward and disclose their offshore accounts for the previous three years and pay only a 5% penalty, not 27.5%.   If the IRS decides your failure to comply with these obligations was willful, you could be socked with a 50% penalty.  In addition, a recent US court decision made it clear that the 50% penalty could be imposed for each year you had an undisclosed international account.”

http://www.nestmann.com/a-ceasefire-in-the-irs-war-on-us-citizens

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