A dual citizen of the U.S. and United Kingdom (“Client”) held bank accounts, pension accounts, life insurance accounts, and an investment account in the United Kingdom in excess of $10,000 while a dual citizen for 11 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.