Resolve Unreported Foreign Income and Accounts Before IRS Enforcement
Unreported foreign income or accounts can trigger severe IRS penalties, even when the failure was unintentional. The IRS offers voluntary disclosure programs that allow taxpayers to come into compliance and reduce or eliminate penalties—provided they act before the IRS initiates contact.
Schedule ConsultationThe Cost of Noncompliance
FBAR Penalties
Up to $10,000 per account, per year for non-willful violations. Willful violations can result in penalties of 50% of the account balance per year.
Failure to File
5% of unpaid tax per month, up to 25% of total liability, for each unfiled return.
Accuracy Penalties
20% of any underpayment resulting from negligence or substantial understatement.
Information Reporting
Failure to file forms like Form 8938 or Form 5471 can result in penalties starting at $10,000 per form, per year.
Criminal Exposure
Willful failure to file can result in prosecution, fines, and imprisonment in serious cases.
IRS Streamlined Filing Procedures
The IRS offers streamlined procedures for taxpayers whose failure to report foreign income or accounts was non-willful. Non-willful means the failure resulted from negligence, inadvertence, or mistake—not intentional disregard of tax obligations.
Streamlined Foreign Offshore Procedures
Available to taxpayers who reside outside the United States and meet the physical presence test (at least 330 days outside the U.S. in one of the three prior years).
This program requires filing three years of tax returns, six years of FBARs, and a certification statement explaining your non-willful conduct.
Penalty Relief: All FBAR and failure-to-file penalties are waived. You pay only tax and interest on unreported income.
Streamlined Domestic Offshore Procedures
Available to U.S. residents with unreported foreign income or accounts.
This program requires the same filings as the foreign procedures but includes a 5% penalty calculated on the highest aggregate balance of unreported accounts.
Penalty Relief: All FBAR and failure-to-file penalties are waived except for the 5% miscellaneous offshore penalty.
Other Disclosure Options
The IRS also offers delinquent filing procedures for taxpayers with late FBARs or international forms but no unreported income, and traditional voluntary disclosure for cases involving potential criminal exposure.
Who Should Consider Voluntary Disclosure
Voluntary disclosure works best when pursued before the IRS initiates contact. Once the IRS begins an examination, eligibility is typically lost.
What We Handle
Return Preparation
We prepare or amend required tax returns, including all international forms necessary to report foreign income, accounts, entities, and trusts.
FBAR Filings
We prepare six years of foreign account reports, reconciling all balances with your tax returns and certification.
International Forms
We handle Form 8938, Form 5471, Form 8865, Form 3520, Form 8621, and other specialized reporting requirements.
Legal Certification
We draft your certification statement explaining non-willful conduct, with review by a tax attorney where appropriate.
Complete Submission
We compile and submit your disclosure package to the IRS and represent you if questions arise.
Why Work With Us
Integrated CPA and Legal Review
Our process includes both tax expertise and legal coordination to ensure accuracy and defensibility.
Complex Case Experience
We handle disclosures involving foreign businesses, trusts, partnerships, and multi-jurisdiction accounts.
Confidential Representation
All communication occurs through secure channels. We represent you if the IRS raises questions.
Global Client Service
We work with clients worldwide using encrypted portals and electronic signatures.
Conservative Approach
We evaluate your case carefully to ensure you qualify for the program you enter.
Voluntary Disclosure FAQs
Act Before the IRS Acts
Voluntary compliance provides penalty relief that disappears once the IRS initiates enforcement. If you have unreported foreign income or accounts, the window closes the moment the IRS contacts you.
Schedule Consultation