The 2011 VDP penalizes dual citizens more heavily than it does domestic U.S. taxpayers.

FORBES: Examining the IRS' New Voluntary Disclosure Program

Additionally, individuals who participated in the 2009 VDP are eligible to receive the benefits of the reduced penalty structure.

FORBES: Examining the IRS' New Voluntary Disclosure Program

However, the 2011 VDP does include the possibility of reduced penalties of 5 and 12.5 percent for certain taxpayers.

FORBES: Examining the IRS' New Voluntary Disclosure Program

It is related to the unfairness of the VDP.

FORBES: IRS Reopens Offshore Amnesty Program For Cheats And Non-Cheats Alike

The story of the past 3 years of IRS voluntary disclosure programs (VDP) are so poorly reported in the press, that I can understand why few understand what really is going on.

FORBES: IRS Reopens Offshore Amnesty Program For Cheats And Non-Cheats Alike

It also has taken up to 26 months for some to go through the VDP process, and that cost in Life Credit Units (LCUs) never gets accounted for on a reconciliation balance sheet.

FORBES: IRS Reopens Offshore Amnesty Program For Cheats And Non-Cheats Alike