Undisclosed Foreign Bank Accounts

Undisclosed Foreign Bank Accounts

Undisclosed Foreign Bank Accounts

Undisclosed Foreign Bank Accounts: When a U.S. person has foreign accounts that they have not properly reported to the IRS, they risk fines and penalties.  In recent years, the Internal Revenue Service has significantly (and aggressively) increased enforcement of offshore compliance on matters involving overseas income, account, assets and investments.  The penalties for being out of foreign accounts compliance can be staggering. Thankfully, the IRS has also developed various amnesty programs to help foreign account holders get into compliance. Collectively, these programs are referred to is voluntary disclosure.

We will summarize how to disclose Undisclosed Foreign Banks Accounts.

How to Report Undisclosed Foreign Bank Accounts

 There are specific methods that taxpayers must use to safely get into compliance and report their unreported foreign accounts or assets.

Currently, there are five main programs available to taxpayers.

It does not matter if the person had to actually file a tax return or not – they can still qualify for the program.

In addition, it does not matter if reside in the United States are outside of the United States. While some programs do require foreign residence, such as the streamlined foreign offshore procedures – there’re other programs available as well.

The current programs include:

Can I Just Report Undisclosed Foreign Banks Accounts Going Forward?


If a person just begins to file forward in the current year without going back and filing in the prior years, it is referred to as a quiet disclosure – and may result in significant fines and penalties, not the least being a Criminal Investigation by the IRS Special Agents.

We Specialize in Offshore Disclosure & Compliance

Our firm specializes exclusively in international tax, and specifically IRS offshore disclosure

We are the “go-to” firm for other Attorneys, CPAs, Enrolled Agents, Accountants, and Financial Professionals across the globe. Our attorneys have worked with thousands of clients on offshore disclosure matters, including FATCA & FBAR.

Each case is led by a Board-Certified Tax Law Specialist with 20-years experience, and the entire matter (tax and legal) is handled by our team, in-house.

*Please beware of copycat tax and law firms misleading the public about their credentials and experience.

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:

  • 20-years experience as a practicing attorney
  • Extensive litigation, high-stakes audit and trial experience
  • Board Certified Tax Law Specialist credential
  • Master’s of Tax Law (LL.M.)
  • Dually Licensed as an EA (Enrolled Agent) or CPA

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.

We specialize in FBAR and FATCA. Contact our firm today for assistance with getting compliant.

    Schedule a Confidential Reduced-Fee Initial Consultation with a Board-Certified Tax Attorney Specialist


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