A U.S. citizen (“Client”) held bank accounts and other financial assets in Spain in excess of $10,000 for over 20 years. Client was not aware of their U.S. tax reporting requirements for foreign assets and never reported taxable foreign income on their U.S. tax returns. Client also failed to file FinCEN Form 114 Report of Foreign Bank and Financial Accounts (FBAR).

DeWitt Law represented Client before the IRS to reach full filing compliance through the IRS streamlined domestic offshore procedures. Three years of amended tax returns and six years of FBARs were prepared and filed as required by the procedures, in addition to a certification of non-willfulness and payment of a 5% penalty on the highest aggregate value of Client’s foreign financial assets. Client reached full filing compliance with the IRS.