There is no one solution for a client who has an unreported offshore bank account. There are a number of alternative routes one may take to come into compliance:
OVDP and Opt-out
Streamlined Process for taxpayers residing outside of the U.S.
Streamlined Process for taxpayers residing in the U.S.
Transitional Rules for those who’ve mailed their OVDP Letter before July 1, 2014.
Do nothing is Statutes of Limitations have run.
Traditional Voluntary Disclosure for those with domestic unreported income.
Optional compliance procedures for those with unfiled FBARS but no unreported income.
Optional Compliance Procedures for those with unfiled information returns but no unreported income.
John J. Scroggin published an interesting and entertaining survey of tax complexity in the Wealth Strategies Journal (Tax Complexity, History, and Humor, July 8, 2014).
The article begins with a quote from Judge Learned Hand:
“In my own case the words of such an act as the Income Tax… merely dance before my eyes in a meaningless procession: cross-reference to cross-reference, exception upon exception—couched in abstract terms that offer [me] no handle to seize hold of [and that] leave in my mind only a confused sense of some vitally important, but successfully concealed, purport, which it is my duty to extract, but which is within my power, if at all, only after the most inordinate expenditure of time. I know that these monsters are the result of fabulous industry and ingenuity, plugging up this hole and casting out that net, against all possible evasion; yet at times I cannot…
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