In more detail
US foreign-account compliance draws a line between non-willful conduct (an inadvertent failure to file) and willful conduct (an intentional disregard of a known legal duty). Non-willful cases generally qualify for the Streamlined procedures, or for reasonable-cause relief on late FBARs, with reduced or no penalties; willful cases carry higher exposure. Classification is fact-specific.
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Does Willful vs Non-Willful apply to your situation?
Cross-border tax turns on the detail of your circumstances. email us and we'll tell you exactly where you stand.