Streamlined Offshore Voluntary Disclosure Procedures For Non-Resident, Non Filer U.S. Taxpayers

Announced by IRS June 26th, 2012.

➜Effective September 1st, 2012.

➜Updated April 26th, 2013

Eligibility

➜ Must have resided outside of U.S. since January 1^st, 2009,

➜ Have NOT filed a U.S. tax return during the same period,

➜ Present a low level of compliance risk,

➜ Must have a valid Taxpayer Identification Number (TIN) which for U.S. citizens and U.S. Resident is a Social Security Number (SSN),

➜ Must owe less than $1,500 of U.S. tax in each of the four years in question,

➜ If accepted under streamlined filing, must file delinquent tax returns for past four years with all appropriate forms including FBARS for the past seven years, AND

➜ Payment for tax and interest must be remitted,

➜ Have not received a letter of audit or investigation from the IRS

➜ Have not received an FBAR warning letter from the IRS

Benefits

➜ If approved as low risk, review will be expedited and IRS will not assert penalties or pursue follow-up actions,

➜ No criminal prosecution if IRS and Department of Justice determine that the taxpayer’s particular circumstances warrant such prosecutions.

For taxpayers concerned about criminal prosecution because of their particular circumstances, consult a legal adviser about the Offshore Voluntary Disclosure Program (OVDP).

Please note: Once a taxpayer makes a submission under Streamlined procedures, OVDP is no longer available. Taxpayers ineligible to use OVDP are also ineligible to participate in the Streamlined procedure.

For more information, please logon to www.irs.gov or www.foodmanpa.com.