Failure to Disclose Foreign Financial Assets

Robert L. Sommers, an experienced tax attorney specializing in foreign tax issues, has produced a Tax Brief aimed at U.S. taxpayers who may have: foreign bank or brokerage accounts; foreign income or assets, or; received (or will receive) a foreign gift or inheritance.

Sommers lays out the filing and reporting requirements under the Internal Revenue Code and discusses the various disclosure initiatives available to taxpayers with unreported income, accounts, gifts or inheritances.

He provides an in-depth analysis of how to determine whether a taxpayer is “willful” in his/her failure to comply with U.S. tax law and the consequences thereof. The Tax Brief is a must read for every U.S. taxpayer is undisclosed foreign accounts or unreported foreign income, gifts or inheritances.