Unreported foreign income. A submission that fits the procedure, with the numbers shown.
Describe what was missed and how. CitedTax tests which procedure fits, sets out the years that remain open, computes the tax, the interest and the 5% offshore penalty, writes the non-willful certification narrative from the client's own account, and lists every return and FBAR to file with it.
- Cost
- 1 credit ($25)
- You provide
- the facts: the accounts or income, the years, the amounts, how it arose, and whether the IRS has made contact
- You receive
- the submission in your firm's name: eligibility, the certification narrative, the year-by-year computation, the offshore penalty, and the filings to enclose
- Turnaround
- about thirty minutes
Credits never expire. A request that fails on our side returns its credits automatically.
Three things to count on.
Streamlined or voluntary disclosure
Non-willful conduct goes to the streamlined procedures; willful conduct goes to the Criminal Investigation practice with its own penalty framework; the letter says which and why.
The years and the penalties computed
The open years under section 6501, the FBAR and Form 8938 penalties that would otherwise apply, and the offshore penalty on the highest balance, shown year by year.
The certification narrative
The reasons the failure was non-willful, written for Form 14654 from the facts, never assumed.
An inherited Italian bank account unreported for seven years
The submission uses the Streamlined Domestic Offshore Procedures, amends the three most recent returns with the income and Form 8938, files six years of FBARs, computes the 5% penalty on the highest balance, claims the foreign tax credit, and explains why the conduct was non-willful.
The same engine, eight other doors.
Every finding cited to primary law
Cited reply to an IRS or state notice
First-time abatement or reasonable cause, IRM cited
A client question answered with the fact-to-law chain
State-by-state matrix or S corp versus LLC on real figures
Protest a proposed adjustment to Appeals, petition the Tax Court, request a CDP hearing
A private letter ruling request in the format the annual revenue procedure requires
A claim for refund that is timely and complete, every ground stated and cited