Client Successes

Streamlined Domestic Offshore Procedure Cases

We have successfully completed over 300 IRS Streamlined Domestic Offshore Disclosure Program submissions for clients since 2014 with assets ranging from $100,000 – $10,000,000 located in over 25 nations.

Successfully completed and received IRS acknowledgment of client’s Streamlined Domestic Offshore Disclosure Program submission including over 10 CFCs (Controlled Foreign Corporations) requiring complex Forms 5471 and 8938 and Forms 926 in the UK.

Successfully concluded and received IRS acknowledgment of second complex (for the same client) IRS Streamlined Domestic Offshore Disclosure Program submission including over 20 PFICs (Passive Foreign Income Company) requiring complex Forms 8621.

Successfully concluded and received IRS acknowledgment of client’s Streamlined Domestic Offshore Disclosure Program submission including over 15 dormant CFCs (Controlled Foreign Corporations) requiring dormant CFC Forms 5471 and 8938 in India.

Successfully completed and received IRS acknowledgment of client’s Streamlined Domestic Offshore Disclosure Program submission with 5 Foreign Trusts requiring complex Forms 3520 in Switzerland.

Successfully concluded and received IRS acknowledgment of client’s Streamlined Domestic Offshore Disclosure Program submission disclosing over $2,000,000 in multiple banks in multiple countries.

Successfully completed and received IRS acknowledgment of client’s Streamlined Domestic Offshore Disclosure Program submission that included 7 Foreign Partnerships requiring complex Forms 8865 and 8938.

Successfully concluded and received IRS acknowledgment of client’s Streamlined Domestic Offshore Disclosure Program submission that included 3 Disregarded Foreign Entities requiring complex Forms 8858 and 8938.

Successfully completed and received IRS acknowledgment of client’s Streamlined Domestic Offshore Disclosure Program submission disclosing 30 FD (fixed deposit) accounts in India.

Successfully concluded and received IRS acknowledgment of client’s Streamlined Domestic Offshore Disclosure Program submission disclosing 2 Public Provident Fund (PPF) accounts in India.

Successfully completed and received IRS acknowledgment of client’s Streamlined Domestic Offshore Disclosure Program submission disclosing 2 Usufruct accounts in Switzerland.

We recently received IRS acknowledgment of client’s Streamlined Domestic Offshore Disclosure Program submission successfully disclosing 10 undeclared non-dematerialized (non-Demat) stock certificates in India.

Successfully concluded and received IRS acknowledgment of client’s Streamlined Domestic Offshore Disclosure Program submission successfully disclosing 15 foreign accounts, foreign earned income, inherited foreign assets, and multiple foreign mutual funds (PFICs) in Singapore.

We recently received IRS acknowledgment of client’s Streamlined Domestic Offshore Disclosure Program submission successfully disclosing substantial value 20 inherited undeclared stock certificates (not dematerialized (non-Demat)) in India.

Successfully completed and received IRS acknowledgment of client’s Streamlined Domestic Offshore Disclosure Program submission successfully disclosing an Isle of Man insurance policy with foreign mutual funds (PFICs).

We recently received IRS acknowledgment of client’s Streamlined Domestic Offshore Disclosure Program submission disclosing 8 undeclared accounts in Spain.

We received notification of the IRS acknowledgment of client’s Streamlined Domestic Offshore Disclosure Program submission successfully disclosing more than 5 undeclared inherited accounts in the U.K. with foreign real estate earnings from multiple UK rental properties.

We recently received IRS acknowledgment of client’s Streamlined Domestic Offshore Disclosure Program submission successfully disclosing 5 undeclared large life insurance policies in India.

We recently received notification of the IRS acknowledgment of client’s Streamlined Domestic Offshore Disclosure Program submission successfully disclosing 9 undeclared dematerialized (Demat) brokerage accounts in India.

We recently received IRS acknowledgment of client’s Streamlined Domestic Offshore Disclosure Program submission successfully disclosing undeclared 3 Provident Fund accounts in Singapore. 

We received IRS acknowledgment of client’s Streamlined Domestic Offshore Disclosure Program submission successfully disclosing 5 undeclared no-interest accounts in Japan.

We recently received IRS acknowledgment of client’s Streamlined Domestic Offshore Disclosure Program submission successfully disclosing 4 undeclared accounts in Costa Rica.

We recently received notification of the IRS acknowledgment of client’s Streamlined Domestic Offshore Disclosure Program submission successfully disclosing 10 undeclared inherited accounts in Spain. The client was previously represented by another firm and came to us after receiving an IRS FATCA letter.

We recently received IRS acknowledgment of client’s Streamlined Domestic Offshore Disclosure Program submission successfully disclosing 8 undeclared accounts in Hong Kong. 

We received IRS acknowledgment of client’s Streamlined Domestic Offshore Disclosure Program submission successfully disclosing 12 undeclared accounts in China.

We can help you too…complete our Foreign Asset Planning Intake Questionnaire to start.

For more information, see our published articles on Streamlined Domestic Offshore Disclosure Program strategies.  While we cannot guarantee any outcome of any case, our clients and other professionals say great things about us… Check out our 5-star rating and testimonials.

Streamlined Foreign Offshore Procedure Cases

Our most successful cases have been IRS Streamlined Foreign Offshore Disclosure Program submissions. We have Successfully concluded over 200 IRS Streamlined Foreign Offshore Disclosure Program submissions since 2014 with foreign assets ranging from $100,000 – $8,000,000 for foreign clientsliving in over 30 countries.

Successfully completed and received IRS acknowledgment of a Streamlined Foreign Offshore Disclosure Program submission for an expat client living in France with substantial assets (over $1,000,000) in multiple banks in two countries. The client was previously represented by another firm and came to us after receiving an IRS FATCA letter.

We recently received notification of the IRS acknowledgment of a complex Streamlined Foreign Offshore Disclosure Program submission successfully disclosing foreign real estate earnings from multiple foreign rental properties for a client living in Ireland.

Successfully concluded and received IRS acknowledgment of IRS Streamlined Foreign Offshore Disclosure Program submission including over 10 PFICs (Passive Foreign Income Company) requiring complex Forms 8621 in Italy.

Successfully concluded and received IRS acknowledgment of client’s Streamlined Foreign Offshore Disclosure Program submission including 5 5 CFCs (Controlled Foreign Corporations) requiring Forms 5471 and 8938 in India.

Successfully completed and received IRS acknowledgment of client’s Streamlined Foreign Offshore Disclosure Program submission with 2 Foreign Trusts requiring complex Forms 3520 in UK.

Successfully concluded and received IRS acknowledgment of client’s Streamlined Foreign Offshore Disclosure Program submission disclosing over $1,000,000 in multiple banks.

Successfully concluded and received IRS acknowledgment of a Streamlined Foreign Offshore Disclosure Program submission for a client living in India with over 50 fixed deposit (FD) accounts in India.

Successfully completed and received IRS acknowledgment of a Streamlined Foreign Offshore Disclosure Program submission for a client living in India with PPF (Public Provident Fund) accounts in India.

We recently received IRS acknowledgment of client’s Streamlined Foreign Offshore Disclosure Program submission successfully disclosing substantial value 10 inherited undeclared stock certificates (not dematerialized (non-Demat)) in India.

We recently received notification of the IRS acknowledgment of client’s Streamlined Foreign Offshore Disclosure Program submission for an expat client living in Hong Kong with 5 undeclared personal Hong Kong accounts. 

We recently received IRS acknowledgment of client’s Streamlined Foreign Offshore Disclosure Program submission successfully disclosing 5 undeclared dematerialized (Demat) brokerage accounts in India.

We received notification of the IRS acknowledgment of client’s Streamlined Foreign Offshore Disclosure Program submission for a client living in China with 7 undeclared personal and business accounts in China requiring complex Forms 5471 and 8938 and Forms 926.

We can help you too…complete our Foreign Asset Planning Intake Questionnaire to start.

For more information, see our published articles on Streamlined Foreign Offshore Disclosure Program strategies.  While we cannot guarantee any outcome of any case, our clients and other professionals say great things about us… Check out our 5-star rating and testimonials.

IRS Penalty Reduction

FULL Abatement of OVDP Penalty: Taxpayer opted out of OVDP. After completing a full-blown audit and follow-up reasonable cause submission, the IRS Agent and Supervisor agreed to a FULL PENALTY ABATEMENT.

5471 Penalty Abatement: Client received a CP215 Notice for $100,000 penalty for numerous late Form 5471 filings for private limited companies in India. We successfully appealed and reduced the penalty to $0.

3520 Penalty Abatement: Client received a CP15 Notice for $125,000 penalty for late Form 3520 filing for an inheritance from China. We successfully appealed with the IRS Office of Appeals and reduced the penalty to $0.

5472 Penalty Abatement: Client received a CP215 Notice for $200,000 penalty for numerous late Form 5472 filings for foreign-owned US corporation. We successfully appealed and reduced the penalty to $0.

3520 Penalty Abatement: Client received a CP15 Notice for $75,000 penalty for late Form 3520 filing for an inheritance from India. We successfully appealed with the IRS Office of Appeals and reduced the penalty to $0.

3520 Penalty Abatement: Client received a CP15 Notice for $250,000 penalty for late Form 3520 filing for an inheritance from Singapore. We successfully submitted a persuasive reasonable cause submission and reduced the penalty to $0.

8300 Penalty Abatement: We successfully represented a client who failed to file Form 8300 Report of Cash Payments Over $10,000.

We can help you too…complete our Tax Planning Intake Questionnaire start.

For more information, see our published articles on Tax Audits, Tax Collection, and tax planning strategies. While we cannot guarantee any outcome of any case, our clients and other professionals say great things about us… Check out our 5-star rating and testimonials.

Tax Minimization and Tax Planning

We have successfully represented many foreign high-net-worth clients prior to US immigration to minimize future US income taxes and foreign asset annual disclosures.

We have successfully represented many foreign high-net-worth families with US-based children in estate planning to minimize future US taxes and foreign asset annual disclosures.

We successfully represented numerous clients who received IRS Letter 6291 “soft letter” (i.e., a warning letter) for US persons owning unreported foreign accounts.

We successfully represented numerous clients who received FATCA letters (i.e., Self-Certification letters) from their foreign bank reporting their financial information to the IRS.

Passport Revocation: Client received a CP508C Notice for passport revocation due to a “seriously delinquent” tax debt. We successfully avoided passport revocation.

We can help you too…complete our Tax Planning Intake Questionnaire to start.

For more information, see our published articles on Tax Audits, Tax Collection, and tax planning strategies. While we cannot guarantee any outcome of any case, our clients and other professionals say great things about us… Check out our 5-star rating and testimonials.