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Can a person enter the Streamlined filing offshore procedures if there was indication of willfullness?

512 views 3 replies 2 participants last post by  Moulard  
Discussion starter
4 posts · ed 2025
Friend of mine opened her one under her other (birthplace) citizenship.
She only has 80k total assets and doesn't owe any taxes yet. She wants to make things right before she stands to lose much more (i.e. her freedom) (potentially in the future if she's discovered).

Can she enter the streamlined program? Is it just smarter to backfile everything and hope for the best?
She got some quotes for the voluntary disclosure procedure and these start at 50k so, plus there's a mandatory willful penalty etc...

Happy to hear all of your thoughts.
 
The Voluntary Disclosure is NOT the same as the Streamlined program. If she is considering coming into US tax compliance, unless she has millions in unreported income voluntary disclosure is not the route to go down.

Broadly streamlined is better than quiet filing, but it really depends on ones personal circumstances.

Both quiet filing and streamlined can be done without professional advice.
 
Yes I am aware that the voluntary disclosure is different.
She is worried about going to jail because she signed documents with her bank saying that she wasn't a US person.
She is happy to just pay all her money to get square and she is worried that if she does the standard streamlined they will nail her on having lied to the bank citizenship
 
Getting up to date on US tax filing requirements will have no bearing whatsoever on the statement made to the bank and I doubt the bank will ever have any means to it was a false declaration.

Unless it was a government form signed under perjury penalities, I would expect it is a matter between her and the bank that at worst would be a civil matter, not something subject to gaol time.

If she is that worried about it, she can make a new declaration to the bank.. and I expect that would be the end of it unless the financial institution does not want to have US persons on its books.

Whether or not she decides to come into compliance for a US tax perspective is entirely a different matter.
 
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