Navigating the intricate regulations of offshore tax compliance can be overwhelming, particularly when you’re at risk of facing significant financial penalties or potential criminal prosecution. Whether you’re dealing with late foreign information reports, unfiled tax returns, unreported foreign income, or have already received a penalty notice, we are here to assist.
We are committed to offering clear advice to reduce the stress associated with the complexities of FATCA, FBAR, and essential IRS international reporting forms such as Forms 3520, 3520-A, 5471, 5472, 8938, and 926.
Our approach involves gaining a deep understanding of your unique circumstances, enabling us to provide personalized support tailored to your situation. After this, we consider the substantive application of the law and provide you with an analysis of the merits and risks of alternative solutions to your issue.
Offshore Penalty Relief
International information reporting penalties are often extreme. We can help advocate for penalty relief through several different procedural alternatives, which depend on the stage of your case.
IRS Voluntary Disclosure Practice (VDP)
The IRS Voluntary Disclosure Practice (VDP) is designed for taxpayers who need to disclose unreported offshore assets and income to avoid potential prosecution. After the close of the IRS’s OVDP program, the VDP is the principal method to come into compliance if you have potential criminal exposure for failure to report foreign assets and income.
Streamlined Domestic Offshore Procedures (SDOP)
Tailored for U.S. residents, the Streamlined Domestic Offshore Procedures (SDOP) offer a pathway to resolve past tax non-compliance issues related to foreign assets and income. This process is crucial for those who have acted non-willfully.
Streamlined Foreign Offshore Procedures (SFOP)
For U.S. expatriates, the Streamlined Foreign Offshore Procedures (SFOP) provide a method to correct previous oversight or omissions of foreign income and assets. This service focuses on taxpayers who were unaware of their filing obligations.
Foreign Gift Reporting & Penalties (Form 3520)
Reporting large gifts from overseas entities can be complex and fraught with penalties if done incorrectly. Our expertise ensures that your reporting meets compliance standards, safeguarding against potential financial penalties.
FIRPTA Liability and Penalty Relief
We assist taxpayers in correcting filing errors and addressing IRS mistakes related to U.S. real estate transactions. Our services focus on securing relief from undue withholding and penalties, ensuring compliance while mitigating financial impacts.
Recent International Tax Cases & News
FBAR Penalties and the Treasury Offset Program: Tax Court Affirms IRS’s Denial of CDP Hearing
