Mr. Sherayzen is a Minneapolis Offshore Disclosure attorney; Sherayzen Law Office is a Minnesota Minneapolis Offshore Disclosure tax law firm. A Minneapolis Offshore Disclosure attorney is also often called IRS Offshore Compliance lawyer. The Minneapolis Offshore Disclosure attorney and Minneapolis IRS Offshore Compliance lawyer are more detailed names for an international tax attorney who is doing an offshore voluntary disclosure in Minneapolis, Minnesota.
Minneapolis Offshore Disclosure: What is Offshore Voluntary Disclosure?
An Offshore Voluntary Disclosure is a process by which a taxpayer voluntarily brings himself into compliance with US tax laws by correcting his prior tax noncompliance with respect to his foreign assets and foreign income. Minneapolis Offshore Disclosure is a merely a variation of this process for a taxpayer who resides in Minneapolis, Minnesota.
Various variations of an Offshore Voluntary Disclosure exist. Given the dynamic nature of US international tax law, these variations are often subject to profound modifications with respect to their terms, penalty amounts and even their very existence. You can find the relevant information for each variation of Offshore Voluntary Disclosure elsewhere on the website. On this page, I will simply list the main options currently available (as of the February 1, 2019) to Minnesota residents who wish to engage in Minneapolis Offshore Disclosure in order to lower or eliminate their IRS penalties.
Minneapolis Offshore Disclosure: OVDP
The 2014 OVDP closed on September 28, 2018. This was the latest version of the flagship IRS Offshore Voluntary Disclosure Program, which dates back to 2003. The earlier versions of the OVDP, however, were not well-known; OVDP’s fame began with the advent of the 2009 OVDP program. Three other variations of the program existed at some point between 2011 and 2018: 2011 OVDI (Offshore Voluntary Disclosure Initiative), 2012 OVDP and 2014 OVDP.
It appears that the closure of the 2014 OVDP means an end to the OVDP as an offshore voluntary disclosure option for a long time. It is possible that another variation may be opened in the future, but there are no indications that this will happen any time soon.
Minneapolis Offshore Disclosure: Streamlined Domestic Offshore Procedures and Streamlined Foreign Offshore Procedures
Streamlined Domestic Offshore Procedures (“SDOP”) and Streamlined Foreign Offshore Procedures (“SFOP”) are two branches of the IRS Streamlined Filing Compliance Procedures. SDOP and SFOP are two related, but different offshore options available for a Minnesota resident who wishes to do a Minneapolis Offshore Disclosure.
Since the closure of the OVDP, these are the main principal voluntary disclosure options. They are available, however, solely to non-willful taxpayers.
Minneapolis Offshore Disclosure: Traditional Offshore Disclosure Program
Taxpayers who willfully failed to comply with their US international tax obligations will find that the closure of the OVDP still left them with one option – the Traditional Offshore Disclosure Program. The Traditional Offshore Disclosure Program underwent a significant change on November 20, 2018, which established a detailed procedural framework for taxpayers who wish to use this option.
Minneapolis Offshore Disclosure: Reasonable Cause Disclosure
The Reasonable Cause disclosure (a/k/a Noisy Disclosure) is still an available option for certain Minnesota residents who wish to do a Minneapolis Offshore Disclosure. Wildly popular prior to the OVDP and between the OVDP programs, the Reasonable Cause disclosure ceded its title of the main OVDP alternative as early as June of 2014 to SDOP and SFOP. Despite its loss in popularity, however, the Reasonable Cause disclosure continues to be an important voluntary disclosure option, especially for taxpayers who are not eligible to participate in SDOP or SFOP.
Minneapolis Offshore Disclosure: Delinquent FBAR Submission Procedures
Minnesota residents who wish to do a Minneapolis Offshore Disclosure can use the Delinquent FBAR Submission Procedures to bring themselves into FBAR compliance in cases where there was no income tax noncompliance. This is a very good option, but it is highly limited by the absence of any de minimis exception to the income tax noncompliance rule.
Minneapolis Offshore Disclosure: Delinquent International Information Return Submission Procedures
Delinquent International Information Return Submission Procedures are similar to the Delinquent FBAR Submission Procedures, but they apply only to information returns other than FBAR. For example, a Minnesota resident can use the Delinquent International Information Return Submission Procedures with respect to Forms 3520, 5471, 8865, 8858, 8938, et cetera. The legal key to this option is having the legal basis for establishing a Reasonable Cause for prior noncompliance.
Contact Sherayzen Law Office for Professional Help With Your Minneapolis Offshore Disclosure
If you are a resident of Minneapolis, Minnesota, and you have undisclosed foreign assets and/or foreign income, you should contact Sherayzen Law Office for professional help as soon as possible. We have successfully helped hundreds of US taxpayers around the world with their voluntary disclosures of unreported foreign assets and foreign income, and We can help You!
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