The IRS's focus on unreported foreign entities and financial accounts is at its highest point at any time in history and continues to escalate. The IRS’s voluntary disclosure practice provides a way for taxpayers to minimize the risks of civil penalties and criminal prosecution due to unreported foreign entities and financial accounts. The government treats taxpayers more leniently if they come forward to fix past problems before they are caught.

Anyone who may have missed a filing requirement should consult with an advisor who is experienced with foreign filing requirements and the IRS's voluntary disclosure practice as soon as possible.


Articles:

IRS Cracks Down on Undeclared Foreign Accounts and Entities

Offshore Misdoings, Repentance, and the US Internal Revenue Service

The Joys of Spring


Forms:

FBAR Disclosure Form

Voluntary Disclosure Optional Format Letter

Form 906 Dissolved Entity FULL Payment


Additional Resources:

IRS Guidelines 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 IRS Commissioner

30 Potential IRS Interview Questions

Most Commonly Missed International Tax Forms

Three Fiscal Years Trends in Criminal Investigations