With the US Internal Revenue Service's (IRS) Offshore Voluntary Disclosure Programme (OVDP) due to close on 28 September, Americans with offshore tax compliance problems are being advised to apply immediately.

The safest way to apply for the OVDI is to make a 'pre-clearance request'. This asks the IRS whether it already has information that disqualifies the taxpayer from participating in OVDI – that is, whether the taxpayer is already being investigated for willful offshore violations. By doing this, the taxpayer can establish their eligibility before revealing any extra information to the IRS.

However, pre-clearance requests take a minimum of 30 days to process, according to the IRS' most recent guidance. So, they must be submitted by tomorrow (24 August) if the taxpayer is to apply safely to use the OVDI, and to find out whether they are eligible...