In order to be eligible for the Streamlined Program, you must provide a sworn statement that your failure to report offshore accounts was not willful. A careful review of your situation must analyze the possibility that the IRS may believe you acted willfully. This is important because the IRS may bring criminal charges if it believes that you willfully failed to disclose your offshore accounts and declare your offshore income. Because of this threat of criminal prosecution careful consideration should be given to the Offshore Voluntary Disclosure Program (OVDP), which provides immunity from criminal prosecution.
If you are trying to decide between the Streamlined Program and the OVDP, contact an attorney who is experienced handling criminal tax defense as well as the OVDP and the Streamlined Program. Contact the Law Offices of Mark L. Horwitz today to discuss your options.
