Protect Your Assets and Reduce Penalties Through Voluntary Disclosure

If you are struggling with the stress of unreported offshore bank accounts or income, or if you fear aggressive audits by the IRS, the SDOP is a powerful voluntary disclosure option that offers a path to compliance and penalty protection.

Don’t feel alone if you are considering voluntary disclosure. Non-willful conduct is often the result of a good faith misunderstanding of the law, negligence, or a simple mistake regarding complex international reporting requirements.

What’s important now is to remediate the issue proactively and find a solution that limits your liability. Our international tax attorneys can help you utilize this voluntary form of remediation to potentially avoid significant penalties.

Call (443) 545-3023 or fill out our brief form for a confidential consultation.

What Does the SDOP Process Entail?

Our international tax experience with voluntary disclosures and IRS compliance can help you get the advice you need to resolve your offshore tax obligations. We’d be happy to walk you through the eligibility and filing process.

Who it Helps & How:

• Eligibility - U.S. Residents & Estates: Designed for U.S. citizens or residents who have filed tax returns for the last 3 years but failed to report gross income from a foreign financial asset.
  • Must not currently be under audit or civil/criminal investigation by the IRS.
• The "Non-Willful" Requirement: Available to taxpayers whose compliance failures were non-willful—meaning they resulted from negligence, mistake, or good faith misunderstanding rather than willful blindness.
  • Allows taxpayers to proactively become compliant without facing harsher fraud penalties.
• The Resolution - Reduced Penalties: Instead of statutory failure-to-file or accuracy-related penalties, eligible candidates pay a Title 26 Miscellaneous Offshore Penalty.
  • This is equal to just 5% of the aggregate balance of the foreign assets, rather than the much higher standard penalties.

Is SDOP the Best Compliance Option for Me?

If you’re uncertain about your eligibility or whether your conduct meets the definition of "non-willful," our international tax attorney team can help you identify the path right for you and help make an informed decision on your best course of action.

There are many factors involved in offshore disclosure, such as residency tests and the specific types of unreported assets (e.g., FBAR, Form 3520, Form 5471). A simple "yes" or "no" isn't always possible without review.

If you do not qualify for SDOP (for example, if conduct was willful), we can explore alternative avenues with you, such as the Voluntary Disclosure Practice.

Complete the form or call (443) 545-3023 today to arrange a private consultation with our skilled tax attorneys.