2019 IRS Streamlined Domestic Program (SDOP) - Should You Apply? (Golding & Golding Board Certified Tax Specialist)

2019 IRS Streamlined Domestic Program (SDOP) – Should You Apply? (Golding & Golding Board Certified Tax Specialist)

2019 IRS Streamlined Domestic Program (SDOP) – Should You Apply?

As the list of Foreign Financial Institutions (FFIs) actively reporting U.S. Account Holders to the IRS continues to grow, the chances of being caught in the FATCA and FBAR matrix is increasing.

2019 IRS Streamlined Domestic Program

With more than 300,000 FFIs currently reporting to the IRS, and more than 110 foreign countries already entering into FATCA Agreements — it may be a good time to consider getting IRS Offshore Compliant.


A few important tips:

Can I submit 2018 Taxes First, and then Get Compliant?

This is a common question, and the answer is, no.


Because if you file 2018 before you submit to voluntary disclosure/tax amnesty, then you are committing a Quiet Disclosure. In other words, you are submitting current year compliant returns, FBARs, etc. without first going back and getting compliant for the prior years.

FBAR penalties can be severe, and a quiet disclosure is just not worth the risk.

IRS the Streamlined Offshore Program Ending?

As recent as the end of 2018, the IRS stated that the Streamlined Program is probably on its way out. Over the past few years, the IRS has indicated the the Streamlined Programs were considered a “Band-Aid” for non-willful account holders to get compliant.

The window of opportunity is to get compliant with the Streamlined Program is slowly slipping away.

Will FATCA be Repealed?

Maybe, but probably not in the immediate future. See recent cases in which Canada upheld FATCA, and France upheld FATCA too.

Increase in Automatic Penalties Being Issued

The IRS has significantly increased the issuance of 5471 (Foreign Corporation) and 3520-A (Foreign Trust) penalties. These penalties can reach into the hundreds of thousands of dollars depending on each person’s individual set of facts and circumstances — and can be issued automatically.

Overall, the chances are greater of avoiding offshore penalties with the Streamlined Program, than trying to abate penalties once they have already been issued.

Consider Offshore Disclosure Before it is Too Late

Depending on the specific facts and circumstances of Peter situation coming he may qualify for one of the four main voluntary disclosure/tax amnesty programs.

While the penalties range extensively, depending on which program Peter qualifies and submits to, overall, it is typically a better result and outcome to enter voluntary disclosure, than to be subjected to a multi-year 50% willful penalty and/or being subject to criminal investigation.

IRS Streamlined Procedures: Domestic and Foreign

The Streamlined Procedures can be broken down into two (2) programs:

Golding & Golding, A PLC

We have successfully represented clients in more than 1,000 streamlined and voluntary disclosure submissions nationwide and in over 70-different countries.

We are the “go-to” firm for other Attorneys, CPAs, Enrolled Agents, Accountants, and Financial Professionals across the globe.