IRS VOLUNTARY COMPLIANCE / IRS VOLUNTARY DISCLOSURE

Lancaster & Reed has over a decade of experience in assisting clients in navigating the complexities of the IRS Voluntary Compliance / Voluntary Disclosure programs. Our depth of experience means no learning curve. In what can be one of the most stressful periods in a client’s life, our goal is to provide clarity to the numbers. We have assisted clients who have participated in all major IRS voluntary compliance / voluntary disclosure initiatives including:

  • • 2003 Offshore Voluntary Compliance Initiative (OVCI)
    • 2003-2008 Last Chance Compliance Initiative (LCCI)
    • 2009 Offshore Voluntary Disclosure Program (OVDP)
    • 2011 Offshore Voluntary Disclosure Initiative (OVDI)
    • 2012 Offshore Voluntary Disclosure Program (OVDP)

Accounting / Tax services provided in conjunction with IRS voluntary disclosure / voluntary compliance programs include:

  • • Forensic accounting for:
    • - Offshore Bank Accounts (We have worked with almost all banks in Switzerland, Caymans, Bahamas, Bermuda, etc. and are very familiar with their statements whether in English, German, French, Spanish or Italian).
      - Foreign Trusts (Grantor & Non-Grantor)
      - Holding Companies & Controlled Foreign Corporations (CFC)
      - Passive Foreign Investment Companies (PFIC)
      - Currency Gain/Loss
  • • Return Preparation
    • - Personal and entity income tax returns
      - Amended returns (personal & entity)
      - Informational returns including:
      • * TD F 90-22.1 (FBAR)
        * Form 3520-A (trust)
        * Form 3520 (trust)
        * Foreign Non-grantor Trust Beneficiary Statement (trust)
        * Form 5471 (CFC)
        * Form 8621 (PFIC)
    • - Penalty & Interest Calculations Including “In Lieu Of” or “FBAR” penalty.

We have assisted clients, and their counsel, in providing accounting services for hundreds of successfully completed voluntary compliance / voluntary disclosure cases. We have completed the accounting for less complicated cases consisting of single foreign bank accounts to the most complex disclosures encompassing multiple foreign trusts with multiple holding companies (including PFIC shares) with assets in excess of $100M dollars. If you are contemplating a disclosure, put our experience and knowledge to work for you!