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International tax · Offshore compliance

Foreign accounts out of compliance? Get current the right way.

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.

Forms & standards
FinCEN 114 (FBAR)Form 8938Form 14654Form 14653Form 8621 PFICForm 5471 · 3520

The forms and rules that come up most often in this practice.

What we handle

The right program depends on your facts

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 advisor
  • Streamlined Domestic Offshore Procedures (SDOP)For US residents whose failure was non-willful: three years of amended returns, six years of FBARs, Form 14654, and a 5% miscellaneous offshore penalty.
  • Streamlined Foreign Offshore Procedures (SFOP)For taxpayers who meet the non-residency test: three years of returns and six years of FBARs with Form 14653, and no offshore penalty.
  • Late FBAR filingsThe IRS retired its Delinquent FBAR Submission Procedures in July 2026. We evaluate whether a Streamlined filing or a reasonable-cause submission best limits penalty exposure.
  • Delinquent international information returnsLate Forms 5471, 8865, 8938, 3520 and 3520-A with reasonable-cause statements.
  • PFIC reportingForm 8621 for foreign mutual funds and similar investments, including mark-to-market and excess distribution calculations.
  • Foreign gifts, trusts and inheritancesForm 3520 reporting for gifts and bequests from foreign persons and distributions from foreign trusts.
  • Voluntary disclosure with counselSupport for the IRS Criminal Investigation Voluntary Disclosure Practice, coordinated with your attorney.
  • Ongoing international complianceAnnual FBAR, Form 8938, foreign tax credit and treaty positions once you're current.

Where we help

Common situations

NRI / NRO

Accounts back home

Bank, fixed deposit and mutual fund accounts in India and other countries that were never reported.

PFIC

Foreign mutual funds

Funds held abroad that trigger PFIC rules and Form 8621.

Inheritance

An inheritance from abroad

Large gifts or inheritances from foreign relatives and the Form 3520 that goes with them.

Business

A company overseas

Ownership in a foreign corporation or partnership that requires Form 5471 or 8865.

Our approach

How the engagement runs.

Confidential review

We list every foreign account and asset and review six or more years of returns.

Choose the path

SDOP, SFOP, delinquent procedures or counsel-led disclosure, explained in writing.

Prepare the submission

Amended returns, FBARs, information returns, PFIC calculations and the non-willful certification narrative.

File and stay current

Submission to the IRS, then annual international compliance going forward.

Questions

Frequently asked

If your question isn't here, call (703) 880-8412 and you'll reach a person.

What is the Streamlined Domestic Offshore Procedure (SDOP)?

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.

How is SDOP different from the Streamlined Foreign Offshore Procedure?

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.

Who is not eligible for the Streamlined procedures?

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.

What counts as non-willful?

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.

Can I still file late FBARs without a penalty?

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.

Do I need to report my Indian bank accounts and mutual funds?

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.

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