Taxpayers with certain undisclosed foreign financial assets can be subject to substantial civil and criminal penalties. If willful noncompliance can be proven, the charges faced also include imprisonment.
We advise our clients as to the most appropriate route for them to come into compliance. We guide them throughout the process and work closely with them, our network of accountants, and the Internal Revenue Service. Our task is facilitated by our team’s experience in both I.R.S. controversy and dealing with the I.R.S. Criminal Investigation Division. Our multi-lingual team coordinates with foreign advisers and foreign financial institutions.
Most of our compliance clients either participate in the Offshore Voluntary Disclosure Program or file under the Streamlined Filing Compliance Procedures, the Delinquent F.B.A.R. Submission Procedures, or the Delinquent International Information Return Submission Procedures. Our team starts by a careful analysis of the facts, followed by a precise selection of the most appropriate accountant for every specific client. We prepare the entire submission package, including penalty calculations when appropriate.
Ruchelman P.L.L.C. provides a wide range of tax planning and legal services for foreign companies operating in the U.S., foreign financial institutions operating ...