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Category: Foreign Assets

Six Guidelines to Writing an SDOP / SFOP Statement of Facts that Will Be Accepted by the IRS

Don’t Be Turned Down for Streamlined Procedures When Trying to Resolve FBAR Reporting Problems If you are thinking about enrolling in the Streamlined Domestic Offshore Procedures (SDOP) or Streamlined Foreign Offshore Procedures (SFOP) in order to resolve delinquent or unresolved FBAR reporting, you will need to be ready to write your “complete story.” That’s because… Read more »

Disclosure Under International Tax Agreements and Tax Treaties

What Does an International Tax Agreement Actually Mean? If you are a US citizen living or doing business in a foreign country, that country probably has at least one international tax agreement with the US. The US has already concluded tax agreements with practically all of the so-called developed countries and the list continues to… Read more »

Panama Papers: A Foreign Asset Disclosure Wakeup Call

The Panama Papers are a collection of documents that were leaked (which essentially means stolen) from Mossack Fonseca, a Panamanian law firm, in 2015 and hit the mainstream media in early 2016. The documents contained information about the offshore assets of a number of wealthy (and sometimes famous) account holders, and the press has mostly… Read more »


New Rules for How to Establish Non-Willfulness for Streamline Program and Other FAQ Updates The most recent updates to the FAQs for the Streamlined Foreign Offshore Procedures (SFOP) and Streamlined Domestic Offshore Procedures (SDOP) have all the trappings of a celebrity scandal, but in fact they serve a far more practical purpose. We’ll get there in… Read more »

How the OVDP Works With Passive Foreign Investment Companies (PFIC)

PFIC Tax Rules – Disclosure Options when you Have Foreign Mutual Funds If you’re a U.S. citizen who has lived or done business outside the U.S. it may have seemed like a good idea to invest in a mutual fund over there, but you need to know the tax rules about passive foreign investment companies… Read more »

Foreign Real Estate and Offshore Disclosure Landmines

Most law-related information on the web comes with a disclaimer towards the end.  When discussing foreign real estate and offshore disclosure, though, I would put the disclaimer at the very beginning: It is strongly suggested that you talk to an attorney with experience in this area. Why at the beginning? Because I want to emphasize… Read more »

Willful on Non-Willful? What Happens Next in the 2015 SFCP or OVDP

The Difference Between Streamlined and full OVDP Think for a second about the Dakar Rally, the world famous off-road endurance race. Challenging terrain, customized vehicles, and long distances are all part of the show. It is obvious to any spectator that it is not an easy race. Drivers need years of experience to compete and… Read more »

Do I Need OVDP?

US Citizen Abroad: Which IRS Forms Should I Have Been Filing? Do I Need to Get Compliant? If you have ever lived outside of the United States you may have noticed that some American calendar dates like Martin Luther King’s Birthday, Columbus Day, or maybe even July 4th start becoming easier to forget. If you are… Read more »

2015 OVDP: Where We Stand

The 2015 OVDP Playbook The 2015 OVDP is essentially the same game but the goalposts have been moved in a big way. FATCA (The Foreign Account Tax Compliance Act) came into effect last July and has been gradually building ahead of steam as it is implemented around the world. Interested in finding out more about… Read more »


U.S. Taxpayers Living Abroad: the 2014 Streamlined Foreign Offshore Procedures For taxpayers living outside the United States, the 2014 OVDP rules bring significant changes to the streamlined program that was available under the 2012 program.  Under the 2014 OVDP Streamlined Foreign Offshore Procedures, like the 2012 streamlined OVDP program, all offshore penalties will be waived… Read more »