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International tax · Offshore compliance
Bank accounts, mutual funds, insurance policies or companies abroad that were never reported can carry large penalties. We assess your facts, choose the right IRS program, and prepare the full submission, usually under the Streamlined procedures.
The forms and rules that come up most often in this practice.
What we handle
The IRS offers several paths for taxpayers with unreported foreign income or missing foreign information returns. The best one depends on where you live, whether the failure was non-willful, and whether any income went unreported.
We review your foreign holdings and filing history and recommend a path in writing. Where a matter could involve willful conduct, we work alongside experienced tax counsel so you have attorney-client protection before anything is filed.
Speak with an advisorWhere we help
Bank, fixed deposit and mutual fund accounts in India and other countries that were never reported.
Funds held abroad that trigger PFIC rules and Form 8621.
Large gifts or inheritances from foreign relatives and the Form 3520 that goes with them.
Ownership in a foreign corporation or partnership that requires Form 5471 or 8865.
Our approach
We list every foreign account and asset and review six or more years of returns.
SDOP, SFOP, delinquent procedures or counsel-led disclosure, explained in writing.
Amended returns, FBARs, information returns, PFIC calculations and the non-willful certification narrative.
Submission to the IRS, then annual international compliance going forward.
Questions
If your question isn't here, call (703) 880-8412 and you'll reach a person.
SDOP is an IRS program for US residents whose failure to report foreign income and assets was non-willful. You file three years of amended returns and six years of FBARs, certify non-willfulness on Form 14654, and pay a 5% miscellaneous offshore penalty based on the highest year-end value of the covered foreign assets.
The foreign procedure is for taxpayers who meet the IRS non-residency test. Filing requirements are similar, but there is no miscellaneous offshore penalty, and the certification is made on Form 14653.
Taxpayers whose conduct was willful, who are already under IRS civil examination or criminal investigation, or who don't have a valid taxpayer identification number generally can't use them. Willful cases may need the IRS Criminal Investigation Voluntary Disclosure Practice with an attorney.
The IRS describes non-willful conduct as negligence, inadvertence, mistake or a good-faith misunderstanding of the law. The certification must explain the specific facts. Writing it carefully is one of the most important parts of the submission.
In July 2026 the IRS removed its Delinquent FBAR Submission Procedures page, which had described penalty relief for late FBARs when all income was reported. Late FBARs can still be filed, but penalty protection now depends more on reasonable cause or on using the Streamlined procedures. Get advice before filing.
US citizens and residents generally must report foreign accounts on an FBAR if the combined balances exceed $10,000 at any time during the year, and may also need Form 8938. Foreign mutual funds are often PFICs that require Form 8621.
Latest updates
FinCEN issued a final rule revising BOI reporting. Business owners should confirm whether their entities still have a filing obligation.
Source: Federal Register
The IRS took down the page that described penalty relief for late FBARs when all income had been reported. Get advice on reasonable cause or the Streamlined procedures before filing late FBARs.
Source: EY Tax News
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