The IRS has established three separate programs under which the American taxpayer can now report foreign bank deposits that have been unreported in the past.
The determination of which of the three relief programs offered by the IRS, is the appropriate program for each individual begins with the legal determination of whether the taxpayer is willful or non-willful.
This is because in the event the taxpayer has been “willful” in their failure to file the appropriate bank reporting accounts, the taxpayer can be subject to a vast array of penalties.
Even the willful taxpayer who is not in compliance to the IRS will be able to come into compliance with the United States laws and avoid the array of penalties that could very well devastate the fortunes of the “willful” taxpayer. The willful taxpayer has the chance to join one of the IRS programs.
The above is an excerpt from Richard S. Lehman’s article The FATCA Team Approach; The Role of Lawyer and Accountant
