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The Bank Secrecy Act of 1970 and subsequent legislation require individuals who hold assets in overseas financial institutions of $10,000 in aggregate value to report these assets to the IRS. Failure to comply with the Foreign Bank Account Reporting (FBAR) requirements can result in large civil tax penalties and potential criminal penalties. In addition, the Foreign Account Tax Compliance Act (FATCA) requires certain U.S. taxpayers holding $50,000 or more in offshore accounts to report those assets.
The federal government has created several Offshore Voluntary Disclosure Programs (OVDP) and streamlined filing procedures allowing foreign account and asset holders to bring themselves into compliance with the reporting requirements and avoid serious penalties. A range of complex considerations can inform whether it is advantageous for a given taxpayer to participate in the OVDP or, instead, to opt out. Either option has risks and should be evaluated according to your particular situation.
Philadelphia, Pennsylvania tax attorney Joseph R. Viola advises foreign account and asset holders; he has extensive experience representing taxpayers seeking to participate in the OVDP and takes great interest in the constant changes and development in this area of tax law. Mr. Viola can advise you in confidence as to your potential civil and criminal exposure as well as navigate you through the complex OVDP process to a satisfactory result. We encourage you to learn more about these areas below and to contact Joseph R. Viola as soon as you become aware of potential foreign bank account issues for a face-to-face consultation.