Are the Streamlined Procedures Ending Soon? A common we receive is, “Are the Streamlined Procedures Ending Soon?” Each year, it seems like the IRS teases taxpayers with the notion that they’re going to end the streamlined filing compliance procedures. For those of you unfamiliar with the program SFCP is an alternative to traditional voluntary disclosure. It is used by non-willful taxpayers who have previous year unreported offshore accounts, assets, and investments.
While it may appear that the IRS is bluffing, they did make good on their promise to end OVDP. That program ended in 2018, and while the IRS also expanded the traditional voluntary disclosure – for some applicants, OVDP would have been a better deal.
As we head into the new year, since the Internal Revenue Service is aggressively enforcing foreign account compliance, it is important for taxpayers to understand the options, and the state of the streamlined program.
Are the Streamlined Procedures Ending Soon?
Recently, the American Bar Association held a conference in Las Vegas. They run this conference each year, and it focuses on issues involving criminal tax and offshore tax related matters. During the conference, one of the head IRS personnel let it be known that the streamlined procedures would be ending. While he did not identify a specific date, it is important to note that this is the same pattern and practice as to what happened before the IRS closed OVDP.
How Much Notice will the IRS Give?
There is no knowing for sure how much notice the Internal Revenue Service will provide to taxpayers. Presumably, the IRS will provide six months notice. As with prior OVDP, that six months does not mean you can submit a placeholder right before the deadline – rather, it means your application must be ready to go by the final due date.
We Specialize in Streamlined Filing Compliance Procedures
We specialize exclusively in international tax, and specifically IRS offshore disclosure.
We have successfully represented clients in more than 1,000 streamlined and voluntary offshore disclosure submissions nationwide and in over 70-different countries. We have represented thousands of individuals and businesses with international tax problems.
We are the “go-to” firm for other Attorneys, CPAs, Enrolled Agents, Accountants, and Financial Professionals across the globe.
- Learn more about the Board-Certified Tax Lawyer Specialist credential
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We are the “go-to” firm for other Attorneys, CPAs, Enrolled Agents, Accountants and Financial Professionals worldwide.
Less than 1% of Tax Attorneys Nationwide Are Certified Specialists
Our lead attorney is one of less than 350 Attorneys (out of more than 200,000 practicing California Attorneys) to earn the Certified Tax Law Specialist credential. The credential is awarded to less than 1% of Attorneys.
Recent Case Highlights
- We represented a client in an 8-figure disclosure that spanned 7 countries.
- We represented a high-net-worth client to facilitate a complex expatriation with offshore disclosure.
- We represented an overseas family with bringing multiple businesses & personal investments into U.S. tax and offshore compliance.
- We took over a case from a small firm that unsuccessfully submitted multiple clients to IRS Offshore Disclosure.
- We successfully completed several recent disclosures for clients with assets ranging from $50,000 – $7,000,000+.
How to Hire Experienced Offshore Counsel?
Generally, experienced attorneys in this field will have the following credentials/experience:
- Board Certified Tax Law Specialist credential
- Master’s of Tax Law (LL.M.)
- Dually Licensed as an EA (Enrolled Agent) or CPA
- 20-years experience as a practicing attorney
- Extensive litigation, high-stakes audit and trial experience
Interested in Learning More about our Firm?
No matter where in the world you reside, our international tax team can get you IRS offshore compliant.
Golding & Golding specializes in FBAR and FATCA. Contact our firm today for assistance with getting compliant.
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