Options Available For U.S. Taxpayers with Undisclosed Foreign Financial Assets

For taxpayers who have undisclosed foreign financial assets and/or income, the IRS provides several options to remedy previous failure to comply with US tax and information reporting obligations. These options include:

•  Offshore Voluntary Disclosure Program (OVDP)
•  Streamlined Domestic Offshore Procedures
•  Streamlined Foreign Offshore Procedures
•  Delinquent FBAR submissions procedures
•  Delinquent international information return submission procedures

Read more about offshore compliance options.

Why Choose Us as your OVDP Tax Attorney?


Before starting my law practice, I worked at a large accounting firm practicing in expatriate and foreign national tax, which is a specialized area of tax. Most OVDP tax attorneys do not understand the accounting aspect of offshore tax compliance. And accountants that do understand expat tax can’t offer you attorney-client privilege, which is vital for individuals with unreported foreign assets. I am able to offer you both.

In addition, only a small percentage of tax attorneys that practice in this area have experience at the IRS. My experience working at the IRS has added significant value to my clients. I know compliance officers, revenue agents, revenue officers, criminal investigators and attorneys at the IRS or that have previously worked there. It helps to have an understanding of the internal operations at the IRS and expertise to tap into if needed.

Personal Attention

Some clients will undoubtedly fall for firms that are more interested in marketing and chasing clients for 5 star reviews than in your case. Unless you’re a sophisticated client, you’ll never know if the optimal tax position was taken on your returns – Were applicable tax treaties reviewed? Were all foreign tax credits included? Could some of the income have been legally excluded? You could walk away impressed that your streamlined or OVDP application was completed quickly and “went through” but what you don’t know is that you may have overpaid your taxes, maybe even by a substantial amount. Our goal is not just to get your application through but also to make sure it’s done with the lowest taxes and penalties assessed.


I have successfully represented clients with offshore assets held across the globe such as in Australia, Canada, Switzerland, Singapore, S. Korea, China, India, UK, Argentina, and elsewhere. We have a 100% success rate in our streamlined and OVDP filings.