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Offshore Voluntary Disclosure, FBAR Delinquent Filings, and Penalties

One of the hot areas of enforcement for the IRS is in the area of undisclosed foreign assets and foreign bank accounts. Through FATCA, the IRS has been working to collect a treasure trove of information from foreign financial institutions and information sharing between these institutions and the IRS is at an all-time high. As such, the IRS has been enforcing a series of penalties, audits, and other actions designed to target those not reporting foreign income or disclosing foreign assets. Even in cases where the mistakes involved are insignificant, the IRS has been known to heavily punish taxpayers for non-compliance by issuing a series of draconian penalties.

Brotman Law understands the complex nature of foreign asset holdings, including determining the value of these assets due to currency fluctuations and other factors. We work to analyze an immediate risk to the client as a result of non-compliance and advocate for a solution that is going to preserve assets and well as to mitigate any potential liability. Whether through the Streamlined Voluntary Disclosure Program or through any number of avenues that may be available to the client, we take a comprehensive approach toward minimizing the risk and cost associated with disclosure to the Service.

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