The first review should establish
- Which tax years and federal returns are affected.
- Which foreign assets and related income were omitted or reported inaccurately.
- Whether FBAR or another international information return presents a separate issue.
- Whether an IRS notice, examination, deadline, or prior submission changes the available path.
- The facts surrounding intent and reasonable cause, without making a premature conclusion.
Correction paths are not interchangeable
Depending on the facts, the relevant IRS procedures may include an amended return, delinquent international information return procedures, streamlined filing compliance procedures, or a different compliance route. Each has its own conditions and consequences.
Streamlined procedures require a non-willfulness certification and have eligibility restrictions. They should not be marketed as automatic amnesty or guaranteed penalty relief.
If you have an IRS notice
Do not use the public form to upload the notice. In your inquiry, provide only the notice type or number, the response date, and a general description. The document itself should move only through an approved secure channel after fit and scope are confirmed.
Potentially willful conduct, an active examination, or criminal exposure requires immediate review by appropriately qualified counsel. This site does not provide legal advice.