- 1 Streamlined Domestic Offshore Procedures (SDOP)
- 2 Streamlined Domestic Offshore Procedures 2019
- 3 Streamlined Domestic Offshore Procedure Lawyers (Krantz Attorneys, Board-Certified Tax Law Specialist)
- 4 Streamlined Domestic Offshore Procedures Penalty Calculation
- 5 Streamlined Domestic Offshore Procedures Eligibility
- 6 Streamlined Domestic is a Form of Offshore Penalty Avoidance
- 7 How Can I Qualify for Streamlined Domestic Offshore Procedures?
- 8 A. Were You Non-Willful?
- 9 B. Did You Previously File “Timely” Tax Returns?
- 10 How to Apply to the Streamlined Domestic Offshore Procedures
- 11 Streamlined Domestic Offshore Procedures 2019 Ending?
- 12 Streamlined Domestic Offshore Procedures FAQ
- 13 Interested in the Streamlined Domestic Offshore Procedures?
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.
- Learn more about the Board-Certified Tax Lawyer Specialist credential
- Learn more about the IRS Enrolled Agent credential
- Learn More about Krantz Attorneys’s Case Accomplishments
- Learn More about Krantz Attorneys Testimonials from prior clients
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:
- FBAR Penalties
- 3520 Penalties
- 3520-A Penalties
- Form 5471 Penalties
- Form 5472 Penalties
- Form 8621 Penalties
- Form 8938 Penalties
- Form 8865 Penalties
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:
- Streamlined Disclosure Common Question & Answer FAQs (lots of them!)
- Summary of FBAR Penalties (with Examples)
- What Happens when you are Willful, but go Streamlined?
- 10 Reasons no to make a “Quiet Disclosure”
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.
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.
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