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Offshore Voluntary Disclosure Program

FBAR Voluntary Disclosure | International Tax Lawyer & Attorney

I often receive calls from prospective clients who talk about FBAR voluntary disclosure. They usually have no clear idea of what is meant by this term and what its requirements are. In this article, I will discuss this concept of FBAR Voluntary Disclosure and explain how this concept covers a variety of offshore voluntary disclosure options.

FBAR Voluntary Disclosure: What is FBAR?

Before we discuss the meaning of FBAR Voluntary Disclosure, we need to understand what “FBAR” is. FBAR is an acronym for Report of Foreign Bank and Financial Accounts, officially known as FinCEN Form 114. US Persons must file FBAR to report their financial interest in or signatory authority or any other authority over foreign bank and financial accounts if the aggregate value of these accounts exceeds $10,000 at any point during a calendar year.

FBAR Voluntary Disclosure: Why FBAR Compliance Is So Important?

US taxpayers who fail to comply with their FBAR obligations may find themselves in an extremely difficult legal position, because FBAR has a highly complex and an exceptionally severe penalty system, which includes even criminal penalties for FBAR noncompliance. The form’s civil penalties include not only willful penalties, but also non-willful penalties – i.e. the IRS can assess FBAR penalties even if a taxpayer’s failure to file his FBARs was unintentional and accidental.

FBAR Voluntary Disclosure: What is Voluntary Disclosure?

“Voluntary disclosure” is a process by which taxpayers voluntarily self-correct their past noncompliance. When this process involves foreign assets, it is called “offshore voluntary disclosure”.

FBAR Voluntary Disclosure: Offshore Voluntary Disclosure Options (Tax Year 2020)

The IRS has created a number of voluntary disclosure programs to encourage taxpayers to come forward and correct their past US tax noncompliance. These offshore voluntary disclosure options include: Streamlined Domestic Offshore Procedures, Streamlined Foreign Offshore Procedures, Delinquent FBAR Submission Procedures, Delinquent International Information Return Submission Procedures (effectively discontinued several weeks ago), IRS Criminal Investigation Voluntary Disclosure Practice (used to be called “Traditional IRS Voluntary Disclosure”) and the now-closed OVDP (Offshore Voluntary Disclosure Process) and OVDI (Offshore Voluntary Disclosure Initiative).

Moreover, there is also a voluntary disclosure based on Reasonable Cause exception that is sometimes called “noisy disclosure”. This is not an official IRS voluntary disclosure program, but simply a voluntary disclosure venue based on specific provisions in the Internal Revenue Code.

Finally, some taxpayers attempt to do “quiet disclosures”. A quiet disclosure can mean a range of actions voluntarily taken by a taxpayer to comply with US international tax laws without officially informing the IRS about his past noncompliance with them. In other words, a taxpayer never takes advantage of any of the voluntary disclosure options and does not claim Reasonable Cause Exception defense; rather, he either files amended tax returns or simply starts to comply with US international tax laws without doing anything about his past noncompliance.

The IRS strongly disfavors quiet disclosures and does not consider them to be voluntary disclosures. In fact, the IRS has officially stated that the agency will try to identify the taxpayers who are doing it and audit them in order to impose penalties for past noncompliance.

FBAR Voluntary Disclosure Versus Offshore Voluntary Disclosure

You probably already noticed that I never listed “FBAR Voluntary Disclosure” as a voluntary disclosure option. The reason is because it is not an official voluntary disclosure option. Rather, FBAR Voluntary Disclosure is merely a term that refers to any offshore voluntary disclosure option involving past FBAR noncompliance (such as Streamlined Domestic Offshore Procedures).

Hence, when a prospective client calls me to discuss his FBAR voluntary disclosure, I know that he does not mean any specific offshore voluntary disclosure program but merely wishes to know what option he should use to voluntarily correct his past FBAR noncompliance.

Contact Sherayzen Law Office About Your FBAR Voluntary Disclosure

If you have not filed your required FBARs for prior years, you should contact Sherayzen Law Office as soon as possible. Sherayzen Law Office is a leader in offshore voluntary disclosures involving FBARs – this is our core specialty.

We have filed thousands of FBARs for hundreds of clients all over the world. We have prepared hundreds of voluntary disclosures under all offshore voluntary disclosure options, including Streamlined Domestic Offshore Procedures and Streamlined Foreign Offshore Procedures. We can help you!

Coronavirus Offshore Voluntary Disclosure: Problems & Opportunities

The advancement of coronavirus in the United States and around the world has significantly disrupted the normal conditions and assumptions for a US taxpayer who engages in an offshore voluntary disclosure of his unreported foreign income and foreign assets. I will refer to a voluntary disclosure conducted in this context of the coronavirus disruptions as Coronavirus Offshore Voluntary Disclosure. In this essay, I would like to discuss the most unique problems and opportunities that arise in the context of a Coronavirus Offshore Voluntary Disclosure.

Coronavirus Offshore Voluntary Disclosure: Most Important Problems

The spread of coronavirus created two important problems to conducting an offshore voluntary disclosure of foreign assets and foreign income.

The first and most significant problem is the ability of taxpayers to obtain the information necessary for the correct completion of US international information returns such as FBAR (FinCEN Form 114), Form 8938, Form 8865, Form 5471, et cetera. Oftentimes, in order to complete these returns, taxpayers have to retrieve information from many years ago.

This is a difficult task even without the coronavirus, because electronic access is often limited to just a few years. In cases that involve small and regional banks, the electronic access to information may simply not exist. Hence, a taxpayer often has to engage in a long process of mailing letters to banks requesting information; it is also a standard practice for taxpayers to personally travel to a foreign financial institution to obtain the necessary information.

The coronavirus prohibitions have made such travel virtually impossible due to cancellation of flights between countries. Even traveling within a country has been severely impacted. Moreover, there have been significant disruptions to ability of taxpayers to access financial institutions in the quarantined areas, such as northern Italy. Many financial institutions have simply closed their branches and ceased to operate in a normal way.

The combination of all of these factors has significantly curtailed taxpayers’ ability to collect the vital information necessary for the completion of an offshore voluntary disclosure.

The second most important problem caused by the coronavirus panic are communication disruptions. During a voluntary disclosure, taxpayers need to have access to their financial advisors and their international tax attorney. I’ve already explained above how the coronavirus bank closures have affected such communications.

The most significant communication issue between a taxpayer and his international tax attorney has been limited to mailing documents, particularly securing an original signature for Certifications of Non-Willfulness, Reasonable Cause Statements, amended tax returns and certain other IRS documents (such as Extension of Statute of Limitations in the context of an IRS audit). The coronavirus containment procedures have affected the flow of regular mail around the world and have caused significant delays in obtaining signed documents from clients.

It should mentioned that the normal communications between a client and his attorney were not significantly impacted. If there were any communication problems, this is most likely the result of the attorney’s failure to take advantage of modern means of communication.

Sherayzen Law Office’s usage of email, phone, Skype, Viber and certain other platforms for information exchange and other modern means of communication has assured continuous and uninterrupted communication between our firm and our clients. We have also encouraged and helped our clients to adopt certain procedures to mitigate other problems that have risen as a result of the coronavirus panic.

Coronavirus Offshore Voluntary Disclosure: Unique Opportunities

The coronavirus panic created not only unusual problems, but also unique opportunities for taxpayers with undisclosed foreign assets and foreign income. I will discuss here the two most important coronavirus opportunities.

First, the spread of this virus has given more time for noncompliant US taxpayers to bring their tax affairs into compliance with US tax laws. Not only has the IRS ability to pursue new international tax cases has been impacted by the virus, but the IRS moved the tax filing deadline to July 15, 2020. This means that taxpayers suddenly have three more months to work on their offshore voluntary disclosures without any interruption with respect to current tax compliance.

Second, more time means that taxpayers now can plan for and adopt more complex and beneficial strategies with respect to their offshore voluntary disclosures. For example, taxpayers who were planning to file extensions can now adopt a strategy to shift their voluntary disclosure period by timely filing their 2019 tax returns and 2019 FBARs.

Contact Sherayzen Law Office for Professional Help With Your Offshore Voluntary Disclosure

If you have undisclosed foreign bank accounts and other foreign assets, contact Sherayzen Law Office for professional help. We have successfully helped hundreds of US taxpayers to bring their tax affairs into full compliance with US tax laws, and we can help you!

Coronavirus & Chinese Offshore Voluntary Disclosures | SDOP Tax Law Firm

March 17, 2020/in Legal Notes, offshore voluntary disclosure lawyers Minneapolis /by Manager

The ongoing coronavirus pandemic has disrupted many areas of human activity around the planet. The coronavirus even affected the IRS offshore voluntary disclosures concerning US taxpayers’ unreported financial assets and income in China (“Chinese Offshore Voluntary Disclosures”). In fact, the impact of coronavirus on the Chinese Offshore Voluntary Disclosures has been severe and extremely disruptive. Let’s look at the top three ways in which coronavirus has disrupted the Chinese Offshore Voluntary Disclosures.

Coronavirus & Chinese Offshore Voluntary Disclosures: Access to Information

The first and most important disruption caused by coronavirus is reduced access to information necessary to complete offshore voluntary disclosures. As a result of the quarantine measures, many financial institutions in China are either closed or work only limited hours. Hence, it has become much harder to obtain relevant information from the Chinese financial institutions, particularly with respect to certain complex investment products and investment insurance policies.

Moreover, as a result of the suspension of travel between China and the United States, many taxpayers are unable to travel to China to obtain the necessary documents. In many cases, internet access to financial data in China is limited to only a few years, whereas taxpayers often need to go back at least six years to obtain the necessary information to accurately complete their delinquent FBARs. In most instances, a taxpayer needs to personally visit his financial institution to collect this older data. At this point, this is almost impossible.

Coronavirus & Chinese Offshore Voluntary Disclosures: Mailing of Signed Documents

With respect to US taxpayers who are currently in China, many of them have limited ability to execute the documents necessary to complete offshore voluntary disclosures and mail them to their international tax attorneys in the United States.

Coronavirus & Chinese Offshore Voluntary Disclosures: Case Schedule

As a result of the two factors above as well as the current communication disruptions in the United States, the coronavirus has caused long delays in the voluntary disclosures that involve undisclosed financial assets in China. The schedule disruptions can last from weeks to months; in fact, in some cases, it is too early to be able to fully assess the impact of coronavirus on an offshore voluntary disclosure schedule.

While Sherayzen Law Office has been able to minimize the impact of coronavirus on the Chinese Offshore Voluntary Disclosures, certain delays still exist due to clients’ inability to obtain the necessary information.

Contact Sherayzen Law Office for Help With Chinese Offshore Voluntary Disclosures

If you have undisclosed financial accounts or foreign businesses in China, contact Sherayzen Law Office for professional help as soon as possible. While the disruptions caused by coronavirus have been severe, by employing careful planning, we can still help you maximize your ability to complete your offshore voluntary disclosure in an accurate and timely manner.

We have already helped hundreds of US taxpayers like you, including in China, to successfully bring their financial and business affairs in full compliance with US tax laws. We can help you!

2020 SDOP Penalty | Offshore Voluntary Disclosure International Tax Attorney

February 28, 2020/in Legal Notes, offshore voluntary disclosure lawyers Minneapolis /by Manager

In an earlier article, I discussed the advantages of the Streamlined Domestic Offshore Procedures (“SDOP”) in the year 2020. Among the advantages, I mentioned the SDOP Miscellaneous Offshore Penalty (hereinafter “SDOP Penalty”), but never explained this concept. The focus of this article is on the 2020 SDOP Penalty and how one generally should calculate it.

It is important to keep in mind that this is an educational article which aims to provide a general overview of the calculation of the Miscellaneous Offshore Penalty in common situations. In providing this general overview of the 2020 SDOP Penalty, the article necessarily glosses over some complex issues that may change the determination of the Penalty in a particular case. In order to calculate your SDOP Penalty properly, the readers should contact Sherayzen Law Office, an experienced international tax law firm, for a legal advice based on their specific facts and circumstances

2020 SDOP Penalty: Background Information

In 2014, the IRS created SDOP as a way to mitigate the harshness of the IRS Offshore Voluntary Disclosure Program now closed (“OVDP”) for non-willful taxpayers. Not only did SDOP offer a shorter voluntary disclosure period and less paperwork than OVDP, but it also replaced the OVDP multi-layered penalty structure with a lower Miscellaneous Offshore Penalty. This SDOP Miscellaneous Offshore Penalty (hereinafter “SDOP Penalty”) stills exists in 2020 and its calculation methodology is still the same (with the exception of a few clarifications provided by the IRS at a later time).

2020 SDOP Penalty: General Description

A taxpayer who utilizes the Streamlined Domestic Offshore Procedures to make the voluntary disclosure of his foreign assets and foreign income must pay a 5% SDOP Penalty. This penalty is paid in lieu of the penalties associated with the delinquent filings of FBARs, Forms 8938, Forms 5471 and other information returns.

The calculation of the SDOP Penalty is very different from calculation of penalties in other offshore voluntary disclosure programs in terms of its time period and the determination of the penalty base. Let’s explore each of these factors separately.

2020 SDOP Penalty: Time Period

The SDOP Penalty equals to 5% of the highest aggregate balance/value of the end-of-year taxpayer’s penalty base (see below) in any of the years in the covered tax return period and the covered FBAR period. Generally, “covered tax return period” is the most recent three years for which the U.S. tax return due date (or properly applied for extended due date) has passed. “Covered FBAR period” means the most recent six years for which the FBAR due date has passed.

Thus, usually, SDOP Penalty is imposed on the past six years covered by the FBAR statute of limitations. However, this is not always the case; in some cases the three-year tax covered tax return period does not completely overlap with the six-year covered FBAR period.

2020 SDOP Penalty: Penalty Base

The concept of “penalty base” is one of most critical considerations in any voluntary disclosure. Generally, penalty base means the assets that are subject to a penalty. Hence when I refer to the SDOP penalty base, I mean the assets which are subject to the SDOP Penalty.

Generally, the SDOP Penalty applies to any foreign financial asset in a given year within the covered SDOP time period if one of the following is true:

The asset should have been, but was not, reported on an FBAR (FinCEN Form 114) for that year;
The asset should have been, but was not, reported on a Form 8938 for that year; or
If the asset was properly reported for that year, but gross income in respect of the asset was not reported in that year.

A foreign financial asset that falls within any one of these three categories should be added to the penalty base.

There are two more important features of the SDOP Penalty base that need to be taken into account. First, the definition of “foreign financial assets” includes not only foreign bank and financials accounts listed on FBAR, but also all foreign financial assets reportable on Form 8938. This means that many more assets in addition to foreign financial accounts may be subject to the SDOP Penalty, including assets listed on Forms 5471 and 8865.

Moreover, the SDOP Penalty base covers more exotic foreign financial assets such as: certain forms of indebtedness issued by a foreign person (such as a note, bond, debenture, an interest in a foreign trust, foreign swaps, foreign options, foreign derivatives, et cetera. The exact determination of what assets should falls in the SDOP Penalty base should be made by an international tax attorney.

The second important feature of the SDOP Penalty is the potential divorce between income tax noncompliance and penalty imposition. Unlike the 2014 OVDP (which closed in 2018), the SDOP Penalty applies to assets which never produced any income. In other words, a bank account that was not reported on FBAR would still be included in the SDOP Penalty base even if it never produced any income.

2020 SDOP Penalty: Calculation of Highest Aggregate Value of Assets

The 2020 SDOP Penalty is imposed on highest aggregate balance/value of a taxpayer’s foreign financial assets that are included in the SDOP Penalty base during the years in the covered tax return period and the covered FBAR period. The calculation of the “highest balance/value” is a three-step process.

First, for each relevant year, you need to determine the end-of-year value of each asset included in the Penalty base. Such value should be in US dollars.

Second, aggregate the end-of-year values/balances per each year in the covered tax return period and the covered FBAR period.

Finally, select the highest aggregate balance/value from among those years and calculate the 5% value of this balance. This is your 2020 SDOP Penalty.

Contact Sherayzen Law Office for Professional Help with Your Offshore Voluntary Disclosure Under Streamlined Domestic Offshore Procedures

If you have undisclosed foreign accounts or any other foreign assets, you should contact Sherayzen Law Office for professional help with your offshore voluntary disclosure. We have helped hundreds of US taxpayers with their offshore voluntary disclosures, including Streamlined Domestic Offshore Procedures, and we can help you!

2020 SDOP Eligibility Requirements | SDOP Tax Lawyer & Attorney

January 20, 2020/in Legal Notes, offshore voluntary disclosure lawyers Minneapolis, Streamlined Domestic Offshore Procedures /by Manager

In a recent article, I mentioned that Streamlined Domestic Offshore Procedures (“SDOP”) will continue to be the most important voluntary disclosure option in 2020 for US taxpayers who reside in the United States. However, not all taxpayers will qualify to participate in the 2020 SDOP. In this article, I will discuss the main 2020 SDOP eligibility requirements.

2020 SDOP Eligibility Requirements: Background Information

The IRS introduced Streamlined Domestic Offshore Procedures in June of 2014 as part of the most radical overhaul of offshore voluntary disclosure process since the introduction of the Offshore Voluntary Disclosure Program (“OVDP”) in 2009.

The IRS created SDOP first to supplement OVDP, not to replace it. The idea was to mitigate the OVDP’s rigidity by streamlining the voluntary disclosure process for taxpayers who non-willfully failed to comply with US international tax requirements.

Almost from the start, SDOP grew in popularity and quickly eclipsed OVDP. Tens of thousands of taxpayers utilized this option to lower IRS penalties in a relatively (i.e. relative to OVDP) fast and painless way. As a result, SDOP continues to exist even today while the 2014 OVDP was closed in September of 2018.

2020 SDOP Eligibility Requirements: Five Main Eligibility Requirements

In order to quality to participate in the SDOP, taxpayers must meet all of the following requirements: (1) US residence; (2) US tax return filing compliance; (3) US international tax noncompliance; (4) non-willfulness; and (5) no IRS examination. Let’s discuss each requirement in more detail.

2020 SDOP Eligibility Requirements: US Residence

In order to participate in SDOP, a taxpayer must be a US tax resident who did not meet any of non-residence tests of Streamlined Foreign Offshore Procedures. This requirements applies differently to two categories of taxpayers.

The first category consists of US citizens and US permanent residents (i.e. “green card” holders). In order to satisfy the 2020 SDOP eligibility requirements, these taxpayers must have a US abode and must not physically reside outside of the United States for more than 329 full days in each of the past three years. I explore what this means further in a future article on Streamlined Foreign Offshore Procedures.

The second category of taxpayers includes all individuals who are not US citizens and US permanent residents. In order for these individuals to be eligible to participate in SDOP, they must satisfy the substantial presence test in each of the past three years. Generally, under 26 U.S.C. §7701(b)(3), an individual meets the substantial presence test if the sum of the number of days on which such individual was present in the United States during the current year and the 2 preceding calendar years (when multiplied by the applicable multiplier) equals or exceeds 183 days. There are many exceptions to this rule, but they are outside of the scope of this article.

2020 SDOP Eligibility Requirements: Filing of US Tax Returns

In order to participate in the SDOP, a taxpayer must have previously filed a US tax return for each of the most recent three years for which the US tax return due date (or properly applied for extended due date) has passed. There is an exception to this rule for situations where a taxpayer’s income was below the tax return filing threshold and he was not required to file the tax return for that year.

2020 SDOP Eligibility Requirements: International Tax Noncompliance

An SDOP disclosure must have some relationship to US international tax noncompliance. A taxpayer must have failed to report income from a foreign financial asset and must have failed to file FBAR or any other US international information return, such as Forms 3520, 3520-A, 5471, 8865, 8938, 8621, 926, et cetera.

2020 SDOP Eligibility Requirements: Non-Willfulness

This is the most important and most difficult eligibility requirement for participating in SDOP: taxpayer’s violations of US international tax law must be non-willful. Moreover, they must be non-willful with respect to each aspect of the voluntary disclosure: FBARs, each international information return and foreign income. In other words, if a taxpayer was non-willful with respect to non-filing of Form 5471, but willful with respect to non-filing of FBARs, then, his entire eligibility to participate in SDOP is compromised.

SDOP provides the following definition of non-willfulness: “non-willful conduct is conduct that is due to negligence, inadvertence, or mistake or conduct that is the result of a good faith misunderstanding of the requirements of the law.” Obviously, proving non-willfulness is a matter highly dependent on facts and requires an individual approach to each client’s case. It is the job of an international tax attorney to make good use of the facts and determine whether non-willfulness can be established.

2020 SDOP Eligibility Requirements: Taxpayer Not Subject to Examination

Finally, a taxpayer who wishes to participate in SDOP must not be subject to an IRS civil examination or an IRS criminal investigation. Whether all relevant years are subject to an examination or just a few of them is irrelevant; it does not even matter whether the examination is focused on a particular international information return. In all of these cases, the taxpayer will most likely lose eligibility to conduct his voluntary disclosure through SDOP.

Contact Sherayzen Law Office for Professional Help With the Determination of Whether You Satisfied the 2020 SDOP Eligibility Requirements

If you have undisclosed foreign accounts or any other offshore assets and you wish to know whether you are eligible to participate in the 2020 SDOP, contact Sherayzen Law Office for professional legal help. Our experienced international tax law firm will thoroughly analyze your case, determine your SDOP eligibility, examine all alternative voluntary disclosure options and skillfully prepare the necessary tax and legal documents necessary to complete your offshore voluntary disclosure.

We have helped hundreds of US taxpayers with their offshore voluntary disclosures, and we can help you!

FBAR Voluntary Disclosure | International Tax Lawyer & Attorney

FBAR Voluntary Disclosure: What is FBAR?

FBAR Voluntary Disclosure: Why FBAR Compliance Is So Important?

FBAR Voluntary Disclosure: What is Voluntary Disclosure?

FBAR Voluntary Disclosure: Offshore Voluntary Disclosure Options (Tax Year 2020)

FBAR Voluntary Disclosure Versus Offshore Voluntary Disclosure

Contact Sherayzen Law Office About Your FBAR Voluntary Disclosure

Coronavirus Offshore Voluntary Disclosure: Problems & Opportunities

Coronavirus Offshore Voluntary Disclosure: Most Important Problems

Coronavirus Offshore Voluntary Disclosure: Unique Opportunities

Contact Sherayzen Law Office for Professional Help With Your Offshore Voluntary Disclosure

Coronavirus & Chinese Offshore Voluntary Disclosures | SDOP Tax Law Firm

Coronavirus & Chinese Offshore Voluntary Disclosures: Access to Information

Coronavirus & Chinese Offshore Voluntary Disclosures: Mailing of Signed Documents

Coronavirus & Chinese Offshore Voluntary Disclosures: Case Schedule

Contact Sherayzen Law Office for Help With Chinese Offshore Voluntary Disclosures

2020 SDOP Penalty | Offshore Voluntary Disclosure International Tax Attorney

2020 SDOP Penalty: Background Information

2020 SDOP Penalty: General Description

2020 SDOP Penalty: Time Period

2020 SDOP Penalty: Penalty Base

2020 SDOP Penalty: Calculation of Highest Aggregate Value of Assets

Contact Sherayzen Law Office for Professional Help with Your Offshore Voluntary Disclosure Under Streamlined Domestic Offshore Procedures

2020 SDOP Eligibility Requirements | SDOP Tax Lawyer & Attorney

2020 SDOP Eligibility Requirements: Background Information

2020 SDOP Eligibility Requirements: Five Main Eligibility Requirements

2020 SDOP Eligibility Requirements: US Residence

2020 SDOP Eligibility Requirements: Filing of US Tax Returns

2020 SDOP Eligibility Requirements: International Tax Noncompliance

2020 SDOP Eligibility Requirements: Non-Willfulness

2020 SDOP Eligibility Requirements: Taxpayer Not Subject to Examination

Contact Sherayzen Law Office for Professional Help With the Determination of Whether You Satisfied the 2020 SDOP Eligibility Requirements

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Archive for category: Offshore Voluntary Disclosure

FBAR Voluntary Disclosure: What is FBAR?

FBAR Voluntary Disclosure: Why FBAR Compliance Is So Important?

FBAR Voluntary Disclosure: What is Voluntary Disclosure?

FBAR Voluntary Disclosure: Offshore Voluntary Disclosure Options (Tax Year 2020)

FBAR Voluntary Disclosure Versus Offshore Voluntary Disclosure

Contact Sherayzen Law Office About Your FBAR Voluntary Disclosure

Coronavirus Offshore Voluntary Disclosure: Most Important Problems

Coronavirus Offshore Voluntary Disclosure: Unique Opportunities

Contact Sherayzen Law Office for Professional Help With Your Offshore Voluntary Disclosure

Coronavirus & Chinese Offshore Voluntary Disclosures: Access to Information

Coronavirus & Chinese Offshore Voluntary Disclosures: Mailing of Signed Documents

Coronavirus & Chinese Offshore Voluntary Disclosures: Case Schedule

Contact Sherayzen Law Office for Help With Chinese Offshore Voluntary Disclosures

2020 SDOP Penalty: Background Information

2020 SDOP Penalty: General Description

2020 SDOP Penalty: Time Period

2020 SDOP Penalty: Penalty Base

2020 SDOP Penalty: Calculation of Highest Aggregate Value of Assets

Contact Sherayzen Law Office for Professional Help with Your Offshore Voluntary Disclosure Under Streamlined Domestic Offshore Procedures

2020 SDOP Eligibility Requirements: Background Information

2020 SDOP Eligibility Requirements: Five Main Eligibility Requirements

2020 SDOP Eligibility Requirements: US Residence

2020 SDOP Eligibility Requirements: Filing of US Tax Returns

2020 SDOP Eligibility Requirements: International Tax Noncompliance

2020 SDOP Eligibility Requirements: Non-Willfulness

2020 SDOP Eligibility Requirements: Taxpayer Not Subject to Examination

Contact Sherayzen Law Office for Professional Help With the Determination of Whether You Satisfied the 2020 SDOP Eligibility Requirements

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