Taxpayer who have previously failed to properly report multinational activities or holdings – in many/most cases for innocuous reasons – enormously benefit from amending prior filings to rectify these issues (to minimize penalty exposures). Fortuitously, the Service offers multiple disclosure programs, some of which are specifically designed for international tax issues. Expert analysis with regards to the disclosure options allows for optimal taxpayer protection – and, very often, disclosures can be made without any additional payments due to the Service.
