Do you have clients who have lived overseas? What about clients who were born in another country, and are now U.S. citizens or residents? If so, chances are they have investments in overseas financial accounts which should have been reported, but weren't. Those who failed to file an FBAR Form TD F90-22.1 are subject to criminal penalties of up to five years in jail, a fine of $250,000 or both.
Even if no criminal penalties are imposed there is still the matter of civil penalties, which can equal three times the balance in the accounts!
- Quiet Disclosures- Are they still viable?
- The Do (Almost) Nothing Approach
- Foreign Retirement Accounts
- Cutting Ties with the U.S. (Not as easy as you might think)
I am a California State Bar Certified Tax Specialist and a former Senior Trial Attorney for the Internal Revenue Service's Office of Chief Counsel. The Firm has advised hundreds of clients with offshore accounts including many who have decided to opt-out of the IRS' OVDP.
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"A Brief Guide to Getting (and Keeping) Your clients with Foreign Connections Out of Trouble, Including FBARS, OVDP, and Lesser Know Issues"
We provide continuing education for CPAs and EAs.
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