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IRS Offshore Voluntary Disclosures


If you are still out of compliance with your foreign accounts or assets, you only have until September 28, 2018 to get back into compliance using the IRS Offshore Voluntary Disclosure Program.   This is the end of the program as we know it and the end of an era in bank secrecy.  

The new world of tax enforcement is going to be much tougher for taxpayers who are still not complying with the law.  The DOJ and IRS have already announced that they are going to be much more aggressive with the sentencing requests in criminal cases.   Instead of pushing for sentences based upon tax non-compliance, the DOJ and IRS will be pushing for sentences based upon FBAR non-compliance.  The sentencing guidelines for FBAR cases are much more aggressive than the tax cases.  

Our Firm can help you get back into compliance with the IRS quickly and quietly while minimizing the expense by negotiating the reduction of penalties and interest. Most of our clients with offshore compliance issues have indicated that they sleep much better at night knowing that they are finally addressing their compliance issues.  

Why should you come back into compliance now?

Not reporting income from foreign sources may be a crime.  The IRS and its international partners are pursuing those who hide income or assets offshore to evade taxes. Specially trained IRS examiners focus on aggressive international tax planning, including the abusive use of entities and structures established in foreign jurisdictions.  The IRS is pushing to ensure U.S. citizens and residents are accurately reporting their income and paying the correct tax. 

What offshore income must be reported to the IRS?

If you are a U.S. citizen or resident alien, you must report income from all sources within and outside of the U.S. This is true whether or not you receive a Form W-2 Wage and Tax Statement,  a Form 1099 (Information Return) or the foreign equivalents.    See Publication 525, Taxable and Nontaxable Income for more information.

Do I have to report offshore bank accounts that are not earning income?

In addition to reporting your worldwide income, you must also report on your U.S. tax return whether you have any foreign bank or investment accounts.  The Bank Secrecy Act requires you to file a FinCen Form 114, Report of Foreign Bank and Financial Accounts (FBAR), if:

  • You have financial interest in, signature authority, or other authority over one or more accounts in a foreign country, and
  • The aggregate value of all foreign financial accounts exceeds $10,000 at any time during the calendar year.

Why should you retain our Firm? 

The main reason is that the IRS is actively looking for taxpayers with offshore accounts. Our Firm has successfully negotiated with the IRS to resolve numerous offshore issues on behalf of our clients with significant penalty abatements and/or reductions. Most importantly, none of our clients have been prosecuted for their non-compliance.

We are tracking the latest offshore news for the following banks:


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