OVDP & SFCP Services and Solutions
Offshore Voluntary Disclosure Program | Streamlined Filing Compliance Procedures
In order to comply with the applicable U.S. law, including tax law, U.S. taxpayers (whether they reside in the United States or outside of the United States) need to cooperate with the IRS, file their delinquent tax returns and disclose any offshore financial assets, as well as pay any taxes owed, including accrued interest and penalties. Doing so proactively, while using one of the IRS amnesty programs, delinquent taxpayers can effectively address their tax situation and avoid hefty penalties (or mitigate penalties quite substantially). More importantly, delinquent taxpayers can ensure that they are not going to be criminally prosecuted for non-compliance.
Notwithstanding the fact that the IRS amnesty programs are open-ended and there is no indication currently that the IRS and the U.S. Department of Treasury will close them, the reality is that these programs may be closed or changed any time. The IRS may or may not give delinquent taxpayers an advance notice, but even if there is a transition period during which delinquent taxpayers may still enter one of the programs to become compliant, it is probably too much of a risk to take. Remember, once the IRS has contacted you or your case is under the IRS examination, the number of options to resolve your tax situation goes down dramatically. And, the cost of becoming compliant rises exponentially.
At the U.S. Tax Law, we provide the following services
- Determination of procedural alternatives available to delinquent taxpayers in becoming compliant based on their facts and circumstances
- Willful conduct determination
- Developing reasonable cause defense
- Using both IRS amnesty programs and assisting clients outside of the program framework to become compliant under applicable tax authorities
- Once the appropriate IRS amnesty program has been identified and confirmed for the delinquent tax payer, the U.S. Tax Law will do everything that is needed to get the taxpayer compliant (including preparation and filing of delinquent tax returns and FBARs, international information returns, non-willful certification, filing the IRS submission, negotiating one’s case with the IRS and IRS Criminal Investigation, and other necessary actions)
- U.S. Tax Law is here to assist with certain aspects of the process, when attorney-client privilege needs to be invoked, as well as to provide legal support, when necessary for any of the IRS amnesty programs.
Have undisclosed offshore foreign accounts or assets?
Know your options after OVDP program closure? Contact our advisors!
Why chose the U.S. Tax Law?
We understand that despite one’s best intentions, when exposed, the IRS may try to assess the highest possible penalties they are allowed to by law. Clearly you must have knowledgeable and highly capable representative on your side to protect you and your assets. Thus, before jumping into any voluntary disclosure and approaching the IRS, having a qualified and experienced U.S. tax attorney and U.S. tax attorney that understands both how the IRS operates internally in addition to all of the pitfalls associated with such a complex legal process is crucial. At the U.S. Tax Law, we have the right expertise and resources to make the disclosure and coming into compliance process seamless, transparent, and manageable. We also know that no matter how daunting your situation may be, we will be able to help. We’ve been there and we’ve seen most of it.