Previous Streamlined Offshore Voluntary Disclosure Program

In response to widespread criticism of the strict penalties associated with the IRS Offshore Voluntary Disclosure programs, the IRS designed a different program for certain qualifying taxpayers.

Non-Resident United States Taxpayers

The Streamlined Offshore Voluntary Disclosure is a procedure designed for taxpayers that represent a low-compliance risk to the Internal Revenue Service. The process is currently available for non-resident U.S. taxpayers who have resided outside of the United States since January 1, 2009 or prior, and who have not filed a U.S. tax return or FinCEN FORM 114, FBAR during that same timeframe. All submissions under the streamlined program will be reviewed; however, the intensity of the review will be determined based on the perceived level of compliance risk.

Taxpayers who qualify for the streamlined procedures are required to file delinquent tax returns for the past three years and file delinquent FBARs for the past six years. A questionnaire, confirming that the taxpayer qualifies for the streamlined procedure, must also be submitted. The questionnaire helps the IRS to determine the compliance risk associated with the taxpayer. Delinquent returns submitted with less than $1,500 in tax liability for each will be considered low-risk by default.

Are You a Non-Resident U.S. Citizen?

The Streamlined Offshore Voluntary Disclosure Program does not provide protection against criminal prosecution, so an analysis of whether the Offshore Voluntary Disclosure Program may be more appropriate given the facts of your case is a necessary step in the decision-making process if you have undisclosed foreign assets and accounts. If you hold an offshore account that you have not previously disclosed or if are a U.S. citizen working overseas and have unreported foreign income, contact the knowledgeable foreign income disclosure attorneys at Brown, PC at 817-870-0025 or toll free at 888-870-0025 to discuss your disclosure options and to schedule a consultation.

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