Through the evolution of tax treaties, the addition of FATCA (Foreign Account Tax Compliance Act), evolving Foreign Financial Asset Reporting requirements, and the increasing actions of reward seeking whistleblowers, the IRS has an ever increasing ability to access foreign information and discovering U.S. foreign reporting non-compliance.
To avoid substantial penalties, including the fraud penalty and the foreign information return penalties, and the increased risk of criminal prosecution by the new requirements, voluntary disclosure is highly recommended where your circumstances so warrant.
Making a voluntary disclosure with the assistance of experienced counsel provides the opportunity to calculate, with a reasonable degree of certainty, the total cost of resolving all offshore issues. The Tax Law Office of David W. Klasing has vast experience in both foreign and domestic voluntary disclosures.