Voluntary Disclosure Program

The IRS Amnesty Program for Undeclared Foreign Accounts and Entities applies to any U.S. citizen or resident who has not properly disclosed foreign entities and accounts in any foreign country, even if the failure to disclose was inadvertent. With the IRS's focus at its highest point at any point in history, the voluntary disclosure practice allows taxpayers to minimize their risks of civil penalties and criminal prosecution due to any unreported foreign entities and financial accounts.

Our International Tax professionals are experienced with foreign filing requirements and the IRS's voluntary disclosure practice. The government treats taxpayers who have come forward to fix past problems more leniently-don't wait to get caught.

2012 IRS Offshore Voluntary Disclosure Initiative

• IRS Reopens Offshore Voluntary Disclosure Program - new!
• IRS Offshore Programs Produce $4.4 Billion To Date for Nation's Taxpayers; Offshore Voluntary Disclosure Program Reopens - new!
• California Voluntary Compliance Initiative 2 (VCI 2) - new!

2011 IRS Offshore Voluntary Disclosure Initiative

• 2011 IRS Amnesty Program for Offshore Accounts and Assets
• U.S. Department of Justice Seeks HSBC's India Bank Account Records
• Second Special Voluntary Disclosure Initiative Announced
• Frequently Asked Questions
• Required Documents and Forms

Articles

• IRS Cracks Down on Undisclosed Foreign Accounts and Entities
• Offshore Misdoings, Repentance, and the U.S. Internal Revenue Service
• The Joys of Spring

Forms

• Report of Foreign Bank and Financial Accounts Disclosure Form
• Voluntary Disclosure Optional Format Letter
• Form 906 Dissolved Entity FULL Payment

Additional Guidance

• IRS Guidance for Voluntary Disclosure
• IRS FAQs
• IRS Memoranda
• FBAR Filing suspended for Non-U.S. Citizens, Residents, or Domestic Entities
• FBAR Administrative Relief for Qualified Individuals with Foreign Financial Accounts or Foreign Commingled Funds
• Statement from the IRS Commissioner
• 30 Potential IRS Interview Questions
• Most Commonly Missed International Tax Forms
• 3 Fiscal Years: Trends in Criminal Investigations