The IRS and Department of Justice are focusing their enforcement efforts on identifying and pursuing individuals and businesses with unreported foreign accounts and foreign assets. failure to have disclosed foreign accounts can lead to severe civil penalties and potential criminal prosecution. There are many opportunities for taxpayers to clean up these issues. We have significant experience in assisting taxpayers with cleaning up past non-compliance with Foreign bank Account Reporting (FBAR) and voluntary disclosure, including use of the IRS offshore initiatives (OVDP and OVDI).
For United States Citizens living abroad who have failed to timely file U.S. federal income tax returns or FBARs, Form TD F 90-22.1, but have recently become aware of their filing obligations and now seek to come into compliance with the law, we can assist them in utilizing either for the Voluntary Disclosure program or the new IRS streamlined filing compliance program. These new procedures are for non-residents including, but not limited to, dual citizens who have not filed U.S. income tax and information returns.
Whether a taxpayer is already under investigation or is considering his or her options in coming clean, we can review their situation and advise them and their tax return preparer on how best to go about handling the issue to minimize penalties and avoid a criminal issue.