International attorneys specializing in Foreign & Domestic Offshore Procedures

The IRS offers a variety of programs, including the Streamlined Filing Compliance Procedures and Voluntary Disclosure Program (VDP), to help taxpayers comply with their tax obligations.

Our experienced team can help you navigate these options and determine the best course of action for your specific situation.

Streamlined Filing Compliance Procedures 2023 FAQ's

If you're a U.S. taxpayer with undisclosed offshore accounts, assets, investments, and/or income, you may be required to file FBAR and FACTA-related forms; unfortunately, many U.S. taxpayers fail to do so. Fortunately, the IRS has developed several tax amnesty programs to help U.S. taxpayers come forward and become compliant.

The Streamlined Filing Compliance Procedures are among the most popular programs for non-willful taxpayers. These procedures provide reduced penalties and streamlined filing requirements for those still needing to comply in prior years.

The IRS introduced the "stand-alone" Streamlined Filing Compliance Procedures in 2014, around the same time foreign countries entered FATCA agreements with the United States. Since then, the IRS has increased enforcement of offshore reporting, and penalties for noncompliance have surged.

Under the Streamlined program, the offshore penalties for failure to file informational returns, such as Form 8938, are forgiven. However, applicants may be subject to a 5% Title 26 Miscellaneous Offshore Penalty if they are not eligible for the Streamlined Foreign Offshore Procedures.

As the IRS aggressively approaches foreign accounts compliance and unreported foreign income, it's crucial to become compliant and avoid offshore penalties. The Streamlined Filing Compliance Procedures can be a practical approach for taxpayers worldwide.

Notre équipe juridique peut vous expliquer comment Les procédures simplifiées de l'IRS fonctionnent et vous aident à naviguer dans le programme. Contactez-nous dès aujourd'hui pour en savoir plus.

The IRS Streamlined Filing Compliance Procedures are designed to help taxpayers become compliant with U.S. tax and reporting requirements. Specifically, the program is intended to assist non-willful taxpayers with foreign income, assets, accounts, and investments to come forward and become compliant. However, taxpayers can also use the program to disclose unreported U.S. income.

Before the availability of the streamlined procedures, non-willful taxpayers were limited to using OVDP or trying to qualify for a narrow "streamlined" exception. The Streamlined Filing Compliance Procedures offer two programs - the domestic and foreign programs- allowing taxpayers to report offshore accounts, assets, and income. The domestic program is intended for non-foreign residents, while the foreign program is designed for foreign residents.

Each program has specific requirements, but both require that the taxpayer's failure to disclose offshore assets, accounts, and income be non-willful.

The updated, streamlined procedures are mainly designed for individual taxpayers, including estates of individual taxpayers. The general eligibility requirements for the procedures for both non-U.S. residents (the "Streamlined Foreign Offshore Procedures") and U.S. residents ("Streamlined Domestic Offshore Procedures") are as follows:

  • Failing to disclose foreign assets, accounts, or income is "non-willful."
  • The IRS has not initiated a civil examination of the taxpayer's returns for any taxable year.
  • The taxpayer pays for the previous penalty assessed against them.
  • The taxpayer has a valid Taxpayer Identification Number.

In order to participate in the Streamlined Filing Compliance Procedures, taxpayers are required to file either three years of amended or original tax returns (for Streamlined Foreign only) as well as informational returns required and also submit six years of FBAR (FinCEN Form 114), form 14653 or form 14654 and Title 26 miscellaneous penalty, if applicable. By meeting these obligations, non-willful taxpayers with offshore accounts, assets, and income can come forward and fulfill their U.S. tax and reporting obligations. This allows non-willful taxpayers with foreign accounts, assets, and income to come forward and become compliant with their U.S. tax and reporting obligations.

Some of the common informational forms required are:

  • FATCA Form 8938
  • Form 3520
  • Form 3520-A
  • Form 5471
  • Form 8865

Click here to visit our FAQ page on Delinquent FBAR Submissions or visit THEVOZ & Partner's main website.

Click here to visit our FAQ page on Delinquent FBAR Submissions or visit THEVOZ & Partner's main website.

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    THEVOZ & Partners specializes in tax law

    This area of law is particularly complex and requires a high level of training. For this reason, our attorneys train continuously and hold a great amount of experience in the field of tax law. THEVOZ & Partners is a tax law firm with offices in Austin and Lausanne specializing in the provision of tax and legal services to individuals and companies in the United States and Europe.

    We help clients navigate a litany of domestic and international tax issues ranging from compliance to planning and even litigation. We understand that each client has unique needs and goals, and we pride ourselves on taking a personalized approach to tailor our services to meet those needs.

    THEVOZ & Partners is an international law firm committed to providing our clients with tailored and competent services.

    THEVOZ & Partners is a highly respected boutique law firm with locations in the United States and Switzerland. Our attorneys have a wealth of experience in various legal fields, with a focus on tax, corporate, and commercial law. We are here to help you with any legal issues; whether you are a business owner seeking advice or an individual needing representation, our team is dedicated to providing personalized, attentive service to all our clients.

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