Resolving Willful Failure to Comply with Tax Obligations to Avoid Prosecution

In a joint effort, Foodman CPAs & Advisors worked with a specialized tax attorney to bring a U.S. executive who had lived in Costa Rica for over 15 years into compliance with the IRS. He had willfully failed to comply with his U.S. tax obligations and was at risk of prosecution.

The Foodman/attorney team determined that the executive qualified for voluntary disclosure. While disclosure does not automatically guarantee immunity from prosecution, it may limit criminal penalties and exposure to prosecution. A voluntary disclosure requires the expertise of a specialized tax advisor—preferably a forensic accountant with financial and investigative skills—working in tandem with a tax attorney.

Timing was of the essence. Voluntary disclosure was a complex two-step process that required our teams' specialized knowledge. The team was contacted by an IRS examiner, and we submitted the documentation and information requested through the tax attorney. Our client is now fully compliant with the U.S. Government.