Reasonable Cause Statement for Offshore Disclosure: When a person is out of compliance for undisclosed foreign and offshore assets, accounts, investments and income, a person is considered “non-compliant.” While the IRS offers various amnesty programs, unless a person qualifies under the strict definition of a non-resident, and can show non-willfulness — they are almost always subject to a penalty.
Some clients feel (understandably so) that any penalty is unfair. Instead of submitting under traditional amnesty programs, they submit a Reasonable Cause package to the IRS.
Reasonable Cause is a complex submission. There are no forms or templates available