On 7 June 2011, the US Internal Revenue Service (IRS) announced new guidance under the existing 2011 Offshore Voluntary Disclosure Initiative (2011 OVDI) originally announced in February. The 2011 OVDI and the new guidance join the arsenal of other weapons the US tax authorities have at their disposal to target non-compliant US taxpayers. Unfortunately and surprisingly, UK-resident Americans who have been fully compliant with their UK tax payment and filing obligations may fall foul of these US tax rules. Here we consider a number of available IRS weapons and how practitioners can best advise their US clients.