PRACTICE AREA
Offshore Voluntary Disclosure & Streamlined Procedures
IRS Voluntary Disclosure and Penalty Relief for Unreported Foreign Assets
U.S. taxpayers who have not reported foreign bank accounts, foreign income, or foreign financial assets face serious civil — and in some cases criminal — exposure. FATCA and the OECD Common Reporting Standard have made undisclosed offshore accounts increasingly visible to the IRS; the assumption that foreign accounts will remain undetected is no longer realistic. We guide clients through the IRS’s available compliance pathways with discretion, strategy, and a focus on achieving the best possible outcome — before the IRS makes contact.
Our Services Include:
IRS Streamlined Domestic Offshore Procedures (SDOP) — for U.S.-resident non-willful taxpayers
IRS Streamlined Foreign Offshore Procedures (SFOP) — for non-U.S.-resident non-willful taxpayers
IRS Criminal Investigation Voluntary Disclosure Program (VDP) — for willful taxpayers
Willfulness analysis and risk assessment — evaluating exposure before selecting a disclosure path
Delinquent FBAR submission procedures
Delinquent international information return submission procedures
Reasonable cause penalty abatement strategies
Coordination with foreign counsel and institutions in multi-jurisdictional disclosure situations