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Streamlined Filing Compliance Procedures

Streamlined Filing Compliance Procedures

Did You Fail to Tell the IRS about Your Off-Shore Financial Matters?


If you have questions about your eligibility for the IRS’ streamlined filing compliance procedures, contact us for your free consultation. 


When you earn income in the U.S., all of your income worldwide is subject to taxation whether or not you’re a citizen. The IRS keeps tabs on this by requiring everyone with foreign financial assets to file a Report of Foreign Bank and Financial Accounts (FBAR) document every year. Failing to do this can get you on the government’s radar pretty quickly, and you’ll have to respond just as fast and carefully to avoid harsh penalties of $10,000 or more for each year you didn’t report.

However, the IRS does recognize that there are some extenuating circumstances, such as someone who has inherited an offshore trust or business entity and legitimately fails to realize that this needs to be reported on a federal level, and they have adopted procedures and broadened eligibility criteria that can reduce or even eliminate the financial penalties owed.

If you’ve found yourself in a position where you non-willfully or even unwittingly failed to:

  • File a Foreign Bank Account Report (FBAR)
  • File a Form 3520
  • File a Form 3520-A
  • File a Form 5471
  • File a Form 8865
  • File a Form 8938
  • Report income from foreign assets

. . .then you may qualify for the IRS Streamlined Disclosure.

At Castro & Co., we can help clients like you with foreign assets or funds undergo the IRS’ streamlined filing compliance procedures to help you certify that you did not willfully fail to file your FBAR or pay your taxes. This is important because the penalties for willfully failing to file your FBAR can be significant or even criminal. When you work with our international tax attorneys, we’ll do our best to help you rest easier knowing that your chances of the best possible outcome are achievable with our assistance.


Contact Castro & Co. online or call (833) 227-8761 to reach out to our attorneys who may be able to assist you with the IRS’ streamlined filing compliance procedures.


The IRS Streamlined Disclosure Process

It’s important to note that only a qualified tax attorney can properly advise you throughout this process and put together the required legal argument for your Certification of Non-Willfulness.

There are several steps to this process and it’s important that each is carefully handled and completed. During our initial consultation, we can walk you through this process, answering any and all questions you might have. The qualification process is key to helping you qualify for the streamlined process in order to reduce or eliminate any penalties you’ve accumulated.

When you choose Castro & Co. to assist in your tax planning, filing, and compliance matters, we’ll ensure that you’re fully covered throughout this entire process. Our comprehensive services are specifically designed to help you:

  • Determine whether you qualify as willful or non-willful - based on the legal standards set forth by statutory law, as well as what has been articulated in case law.
  • Write a persuasive Certification of Non-Willfulness - it will be important to show the examiner that the IRS cannot prove that your failure to file was not willful, which is needed to approve the Streamlined Filing.
  • Put together a collection of relevant evidence - since this is typically determined by circumstantial evidence, we maintain a full understanding of the statutory law, case law, and the current IRS thinking over qualifying evidence.
  • Oversee the proper amendment of three years of tax returns - inclusive of foreign retirement plans, foreign annuities, and closely-held business interests, among others.
  • Preserve attorney-client privilege - communication with your accountant can and will be obtained by the IRS. By partnering with a true tax attorney, your rights will be upheld.
  • Prepare all the necessary documentation for your submission - this will include amended returns, FBARs, Forms 3520, 3520-A, 5471, 8621, 8865, and 8938, as well as all the supplementary Streamlined Disclosure documentation.

If you have questions about your eligibility for the IRS’ streamlined filing compliance procedures, contact an attorney from Castro & Co. to get the specific and personalized attention you need.


  • ABC News
  • CBS News
  • U.S. News & World Report
  • The Wall Street Journal
  • International Bar Association
  • Bloomberg Business
  • SMSF Adviser
  • The Sydney Morning Herald
  • Tax Analysts

Be Prepared. Don’t Wait Until You’re Audited.

Whether you’re just beginning the process or have already been contacted by the IRS, we are dedicated to providing you efficient, effective, and confidential representation for your voluntary disclosure in addition to protecting you through the entire process and enabling all communication with the IRS to go through our firm.

It’s important that you realize the risks that can come along with submitting a streamlined filing - especially if you try to complete one yourself or without the assistance of a qualified tax attorney. If the IRS finds that you are ineligible, it could trigger an audit or investigation, which will bring far more stress, frustration, and trouble. This is why it’s so vitally important that you consult with a qualified tax attorney before taking any steps in this direction.

If you find yourself in a situation where you:

  • Have been contacted by IRS or another federal department or agency regarding offshore holdings
  • Need to discuss your options under the 2018 IRS Voluntary Disclosure Program
  • Are interested in discussing whether or not you’re eligible for a streamlined filing
  • Would like to discuss whether or not you need to report your foreign financial assets

What Sets Castro & Co. Apart from Others?

Aside from Streamlined cases, we are dedicated to offering exceptional customer service and that means being a one-stop-shop for all of our clients’ taxes and financial needs.

We offer:

  • Free Estate Planning
  • Free Consultations
  • Free Advisement on Structuring your Business in a Tax-Efficient Manner

In addition, we offer 100% protection from the IRS if they decide to audit you. As a tax law firm, we are prepared to litigate any issues with the IRS and have submitted thousands of cases while maintaining a 100% success rate. Unlike accounting agencies who aren’t prepared to go toe-to-toe with the IRS, we ensure that our clients never have to actually speak with the IRS, since we’ll stand by their side throughout the process, offering them optimal protection.

It’s this customer service attitude that has led us to become one of the most reliable and well-trusted firms across the world. When you decide to put us on your team, you ensure that nothing is left to chance. We’ll help you remain compliant and safe throughout all your IRS dealings.


Please call us directly at (833) 227-8761 or use the form below to submit a contact request or to request your free consultation.


The Castro & Co. Difference
  • Free Consultations
  • Experienced & Thoroughly Published Attorneys
  • Innovative Solutions
  • Sophisticated Global Tax Planning
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