Many US taxpayers are being advised to jump into the streamlined domestic offshore procedures relating to offshore investment income and assets. The streamlined program offers significantly lower penalties and interest, and may be an effective option for some taxpayers. There are cases where you should not consider the streamlined option, and where it can leave the door to the statute of limitations and potential criminal exposure. The modified OVDP limits the look back period to 3 years, and while they may make life miserable for you while they work through your returns, in the end the program agrees to limit your exposure to 3 years. This can make a substantial difference in the amount owed based upon balances in your accounts prior to that period, as well as the potential for criminal tax exposure.
This is a unique and historic time from the perspective of offshore income and investments and the IRS. The game has substantially and forever changed. The IRS has deep access to information, and will be knocking at your door. It’s just a matter of time. This isn’t a decision to rush through. This is a complex evaluation of financial holdings, timeframes, reporting anomalies and coming into compliance. Call the experienced proven tax attorneys at Allen Barron for a free consultation at 866-631-3470. We will extend the attorney-client privilege to protect your interests while we have an open and candid discussion about your holdings and the best options available for you to come into compliance.