Streamlined Domestic Offshore Procedures 2019 - How to Qualify? (Krantz Attorneys, Board-Certified)

Streamlined Domestic Offshore Procedures 2019 – How to Qualify? (Krantz Attorneys, Board-Certified)

Streamlined Domestic Offshore Procedures 2019 – How to Qualify?

Streamlined Domestic Offshore Procedures: The IRS Streamlined Domestic Offshore Procedures or (SDOP) are an efficient and cost-effective method to quickly get into IRS (Internal Revenue Service) or DOT (Department of Treasury) compliance for offshore accounts, assets, investments or income — before it is too late.

Streamlined Domestic Offshore Procedures (SDOP)

We receive many inquires about the IRS Streamlined Domestic Program — which is U.S. residents (aka non-foreignrResidents). Before making a disclosure submission, it is important to understand what the term Streamlined Domestic Offshore Procedures (SDOP) means.

SDOP is also referred to as:

  • IRS Streamlined Domestic
  • Streamlined Filing Compliance Procedures
  • Streamlined Procedures
  • Streamlined Disclosure
  • IRS Streamlined Amnesty Program

Streamlined Domestic Offshore Procedures 2019

In 2019, the Streamlined Domestic Offshore Procedures is still (currently) available.

The Streamlined Domestic Program allows individuals to come into IRS tax and reporting compliance, without having to pay any penalties.

When a U.S. person is out-of-compliance with the IRS for unreported foreign accounts, assets, income, and investments, the applicant may qualify for one of the IRS Streamlined Programs (aka Streamlined Filing Compliance Procedures).

Streamlined Domestic Offshore Procedure Lawyers (Krantz Attorneys, Board-Certified Tax Law Specialist)

Krantz Attorneys represents clients worldwide in over 70-countries exclusively in Streamlined, Offshore and IRS Voluntary Disclosure matters. We have successfully completed more than 1,000 streamlined and voluntary disclosure submissions.

We are the “go-to” firm for other Attorneys, CPAs, Enrolled Agents, Accountants and Financial Professionals worldwide.

Less than 1% of Tax Attorneys Nationwide Are Certified Specialists

Ezra Krantz is one of less than 400 Attorneys (out of more than 200,000 practicing California Attorneys) to earn the Certified Tax Law Specialist credential. The credential is awarded to less than 1% of Attorneys.

Streamlined Domestic Offshore Procedures Penalty Calculation

If you are seeking to learn specifically how to calculate the penalty we have a separate article detailing the Streamlined Domestic Offshore Procedures Penalty Calculation.

Streamlined Domestic Offshore Procedures Eligibility 

The IRS Streamlined Procedures can be broken down into two (2) main programs: Streamlined Domestic Offshore Procedures, and Streamlined Foreign Offshore Procedures.

The Streamlined Domestic Offshore Procedures are used by U.S. Residents (non-foreign residents).

What is the Benefit of “Going Streamlined”

The purpose of the Streamlined Domestic Program is to leverage a smaller penalty now, against a potentially larger penalty later — noting that in recent years, the IRS has become much more aggressive in enforcing FBAR and offshore penalties.

By proactively submitting a Streamlined Domestic submission, you voluntarily pay a “5% Streamlined Penalty” up-front, to avoid a potentially much larger penalty in the future.

While not everybody gets hit with offshore penalties, the IRS has increased enforcement of penalties.

Streamlined Domestic is a Form of Offshore Penalty Avoidance

Here is a brief list of the potential penalties you can get hit with by the IRS:

IRS Streamlined Domestic for U.S. Resident - Avoid a Larger Offshore Penalty

IRS Streamlined Domestic for U.S. Resident – Avoid a Larger Offshore Penalty

How Can I Qualify for Streamlined Domestic Offshore Procedures?

The eligibility requirements to qualify for the Streamlined Domestic Program can be broken down further into the following elements:

A. Were You Non-Willful?

Generally, if a person was unaware that there was a foreign account, foreign income, or foreign asset reporting requirement, the applicant may qualify as non-willful.

Unfortunately, there is no bright-line test, and a more complex “totality of the circumstances” analysis is required.

Non-Willful vs. Lower Standards of Willfulness 

Willfulness does not mean intent.

There can be “lower” forms of willfulness, which do not require willful or intent — these additional willful standard are referred to as:

B. Did You Previously File “Timely” Tax Returns?

In order to qualify for the Streamlined Domestic Offshore Procedures, a person must have previously filed tax returns, and they must have been filed “timely,” when they were originally filed.

If you meet the requirements of A. and B. above, then you may qualify for the Streamlined Domestic Offshore Procedures.

*The “timely return” requirement does not apply to the Streamlined Foreign Offshore Procedures.

How to Apply to the Streamlined Domestic Offshore Procedures

If you previously filed U.S. Tax Returns “timely,” and are non-willful you generally qualify for the Streamlined Program.

The Taxpayer is required to file original or amended tax returns, file all necessary international reporting forms, and prepare a non-willful certification on IRS Form 14654 to reduce their Non-Willful Title 26 Miscellaneous penalty to 5%.

*Applying to the Streamlined Domestic Offshore Procedures can be deceptively more complex than it may appear at first glance.

Streamlined Domestic Offshore Procedures 2019 Ending?

There is no knowing if the Streamlined Domestic Offshore Procedures Ending date is coming now, or later. BUT, the IRS reserves the right to end the program at any time and has indicated that the program “won’t last forever.”

Streamlined Domestic Offshore Procedures FAQ

Here are some additional resources to assist you in your research journey:

Golding & Golding (Board Ceritfied Specialist in Tax Law)

Krantz Attorneys (Board Certified Specialist in Tax Law)

Interested in the Streamlined Domestic Offshore Procedures?

No matter where in the world you reside, our international tax team can get you IRS offshore compliant. 

Krantz Attorneys specializes in Streamlined Domestic Offshore Procedures. Contact our firm today for assistance with getting compliant.


International Tax Lawyers - Krantz Attorneys, A PLC

International Tax Lawyers - Krantz Attorneys, A PLC

Krantz Attorneys: Our international tax lawyers practice exclusively in the area of IRS Offshore & Voluntary Disclosure. We represent clients in 70+ different countries. Managing Partner Ezra Krantz is a Board-Certified Tax Law Specialist Attorney (a designation earned by < 1% of attorneys nationwide.). He leads a full-service offshore disclosure & tax law firm. Ezra and his team have represented thousands of clients nationwide & worldwide in all aspects of IRS offshore & voluntary disclosure and compliance during his 20-year career as an Attorney.

Ezra holds a Master's in Tax Law from one of the top Tax LL.M. programs in the country at the University of Denver. He has also earned the prestigious IRS Enrolled Agent credential. Mr. Krantz's articles have been referenced in such publications as the Washington Post, Forbes, Nolo, and various Law Journals nationwide.
International Tax Lawyers - Krantz Attorneys, A PLC

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