The Streamlined Filing Compliance Procedure (SFCP) was “born” two years old. Two years ago the IRS publicly announced the SFCP, which has been used by many non-compliant US taxpayers with the disclosure of foreign assets. SFCP has two sub-programs: one
We have had many clients with unreported foreign mutual funds. As a result, it is time to revisit the unfavorable topic of foreign mutual funds as a “Passive Foreign Investment Companies” (PFICs), which is often a surprise to our clients. U.S.