Streamlined Domestic Offshore Program

The IRS Streamlined Domestic Offshore Procedures provide a path for U.S. taxpayers with unreported foreign financial accounts to come into compliance with reduced penalties. Philip Falco specializes in bringing non-compliant taxpayers with foreign accounts into compliance through this program.

Who Qualifies?

• U.S. taxpayers (individuals) residing in the United States
• Taxpayers who have failed to report foreign financial assets and pay tax on income from those assets
• Taxpayers whose failure to comply was non-willful (not due to willful conduct)
• Taxpayers who have not been contacted by the IRS regarding the delinquent returns

What Is Required?

• Amended returns — file amended tax returns for the most recent 3 years
• Delinquent FBARs — file delinquent FBARs (FinCEN Form 114) for the most recent 6 years
• Miscellaneous offshore penalty — pay a 5% penalty on the highest aggregate balance of unreported foreign financial assets
• Certification statement — certify that the failure to report was non-willful

Why Use an Attorney?

The certification of non-willfulness is a critical legal document. If the IRS challenges your certification, attorney-client privilege protects all communications with Philip Falco during the preparation process. A CPA does not have this same level of protection in criminal matters.

As a dual-licensed Attorney and CPA, Philip Falco handles both the legal and tax preparation aspects of the streamlined procedures, ensuring your submission is complete, accurate, and properly documented.

Call (303) 626-7000 to discuss your foreign account compliance options.