A U.S. citizen (“Client”) held certificate of deposit accounts for 9 years in China worth in excess of $1,000,000. Client’s accountant never reported taxable foreign income on Client’s U.S. tax returns. The accountant also failed to prepare or 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.