[IMGCAP(1)]Many tax practitioners will meet holders of foreign accounts who have either deliberately or unintentionally failed to accurately report their foreign accounts and will need to advise them on the best way to make the disclosure to the Internal Revenue Service.

Due to the fact that many U.S. taxpayers have not reported their income from foreign financial accounts, the IRS has implemented two programs that allow U.S. taxpayers to bring themselves into compliance with the Internal Revenue Code and the Bank Secrecy Act. Each program has its own ramifications and penalties. The two programs—the Offshore Voluntary Disclosure Program and the Streamlined Offshore Disclosure Program—are exclusive. If you participate in one, you cannot participate in the other.

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