The IRS’s FATCA, Streamlined Compliance Procedure and other Amnesty Information

Amnesty Offshore Voluntary Disclosure Program.  American citizens and residents often have placed funds in “foreign bank accounts” in banks all over the world.  There is a requirement that all of these foreign bank accounts be reported to the United States on an annual basis and that United States income taxes be paid on all of these bank deposit funds.

Many American taxpayers who have been unaware of this requirement are now being pursued for taxes and penalties for not reporting their foreign bank deposits.  There are two Internal Revenue procedures that will permit American taxpayers, who have not properly reported their foreign bank deposits, and the income therefrom, to come forward and report their foreign bank deposits.  This avoids significant fines and penalties on a United State taxpayer who has not reported foreign bank deposits.

There is a program for those United States depositors who have knowingly evaded reporting their foreign bank deposits.  This program is known as the Offshore Voluntary Disclosure Program and has strict requirements because of the fact that the non reporting was knowingly and willfully made.  This “Amnesty Program” has strict penalties that are much less than all of the penalties that could have been inserted.

Below is a short 5-minute segment on the topic Amnesty Offshore Voluntary Disclosure Program


There also is an Internal Revenue Service program that permits United Staes individuals, who have innocently and unknowingly not reported their foreign bank deposits, to report those deposits at a much reduced penalty than the penalty applicable to the willful violators.

Below is a short 3-minute segment on the Streamline Compliance Program


Below is a full 1-hour presentation

Presentation Resources: Download a set of presentation slides (50 pages): Download as pdf

Articles by Richard S. Lehman Esq:

  • I.R.S. Makes Changes To Offshore Bank And Foreign Asset Disclosure Programs Read online
  • The Foreign Account Tax Compliance Act (FATCA): Americans now required to disclose all foreign financial assets Read article online
  • Foreign Financial Institutions: Reporting and Withholding United States Taxes Read article online
  • The Amnesty Program for Unreported Foreign Income Read article online

Bonus I.R.S. Materials:

United States Treasury Decision 9567: IRS Temporary Regulations on reporting of specified foreign financial assets.

Instructions for Form 8930: Statement of Specified Foreign Financial Assets.

The New Treaty and Annex: download pdf -31 pages includes:

  • Model Intergovernmental Agreement to Improve Tax Compliance and to Implement FATCA
  • ANNEX 1: Due diligence obligations for identifying and reporting on U.S. Reportable accounts and on payments to certain non participating financial institutions
  • ANNEX 2: Non-reporting [FATCA Partner] Financial Institutions and Products

IRS “Amnesty” Questions:

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