Value-priced IRS voluntary disclosure practice

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Where the conduct was not non-willful, the streamlined programmes are unavailable and the voluntary disclosure practice is the route that addresses criminal exposure. Value-priced IRS voluntary disclosure practice with a fixed fee agreed in writing before any work starts. Call the 24-hour helpline on +1 (416) 619-0068, or request a written quote today.

+1 (416) 619-0068 See fixed fees
  • 15+Years of cross-border experience
  • 18,000+Clients served
  • 5.0Google rating
  • 4Global offices — India, USA, Canada & UAE
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Secure a fixed quote

Start by sending whatever paperwork exists — a written fixed quote comes back before any work begins.

24-hour helpline: +1 (416) 619-0068
  • Fixed fee agreed before work starts
  • 18,000+ clients served
  • Offices in India, the USA, Canada and the UAE
The short answer

Where the conduct was not non-willful, the streamlined programmes are unavailable and the voluntary disclosure practice is the route that addresses criminal exposure. It runs in stages, beginning with a pre-clearance request, and it produces a defined civil penalty framework rather than penalty relief.

Who has to deal with this

  • One or more years, returns or information reports are unfiled
  • You have received a notice, a query or a reassessment
  • Accounts or income abroad were not reported
  • You want to correct a position before the authority finds it
  • You have already filed something and are not sure it helped

If more than one of those is true, this is your page. If none of them is, tell us on a call and we will point you at the right one — that happens often enough that we would rather you asked.

Two of the firm’s advisers and the team in the open-plan office

What IRS voluntary disclosure practice costs here

Voluntary disclosure is priced in stages because it runs in stages: pre-clearance first, then the disclosure itself, then the examination that follows. What moves the figure is the number of years and entities inside the disclosure period, and how much of the record has to be rebuilt before anything is submitted.

Streamlined catch-up — 3 years + 6 FBARs — fixed-fee price

From $449

fixed, quoted before work starts

The full streamlined submission: the back returns, the account reports for the whole period, and the non-willfulness certification that is the substance of the application.
See the full fee page

CRA voluntary disclosure package — fixed-fee price

From $349

fixed, quoted before work starts

The disclosure application with the corrected filings, a documented chronology of how the failure arose, and representation through to the CRA's decision.
See the full fee page

Catch-up & voluntary disclosure

From $349

fixed, quoted before work starts

Late and unfiled years, sequenced and filed together, with the relief available for the delay identified before the first return goes in.
See the fee schedule

Foreign asset & information reporting

From $349

fixed, quoted before work starts

Foreign holdings mapped once — accounts, real property, shareholdings — then reported to each authority in the form it requires.
See the fee schedule

Individual tax filing

From $349

fixed, quoted before work starts

Individual returns where salary, investments or property sit outside the country of residence, prepared so relief is claimed once and in the right place.
See the fee schedule

Non-resident & departure filings

From $349

fixed, quoted before work starts

For anyone taxed by a country they do not live in — rent, pensions and investment income reaching across a border after the move.
See the fee schedule

Corporate cross-border filing

From $999

fixed, quoted before work starts

Returns for companies with foreign subsidiaries, foreign income or foreign shareholders, and the schedules each of those triggers.
See the fee schedule

Payroll & mobility setup

From $999

fixed, quoted before work starts

Registrations, withholding and the employer obligations that follow staff working across a border, set up once and correctly.
See the fee schedule

All published fees on one page — the complete list of what each engagement costs, stated as figures rather than ranges.

Why the answer comes out the way it does

Where the conduct was not non-willful, the streamlined programmes are unavailable and the voluntary disclosure practice is the route that addresses criminal exposure.

It runs in stages, beginning with a pre-clearance request, and it produces a defined civil penalty framework rather than penalty relief. Because criminal exposure is the reason it exists, the analysis belongs with counsel before anything is filed.

What that means in practice is that the work happens before the filing season, not during it. By the time a return is being prepared the facts are fixed; everything that could have changed the answer — a date, an election, a certificate, a valuation — had its own window, and most of those windows close earlier than people expect.

The standard here is simple: no figure without a source for your year. Anything that cannot meet it is written as a mechanism, so you can see exactly what the rule does even where the number has to be confirmed before filing. See also form t4a-nr summary and form ss-4 — EIN application.

What we actually file

  • Correspondence and representation through to closure
  • An eligibility assessment across every route before anything is filed
  • Amended returns where amendment rather than disclosure is the right vehicle
  • Objections or appeals where an assessment has already issued
  • A written record of what the authority will see, and in what order

The numbers, end to end

This is what the rule produces when you put figures through it.

How an information-return exposure compounds

A filer who owed no tax at all, but missed an information return for 8 years with 3 forms due each year. Assume a per-form penalty of US$4,000 for the illustration.

ItemAmount
Years unfiled8
Forms due per year3
Assumed penalty per formUS$4,000
Exposure before any reliefUS$96,000
Tax actually owed on the incomeUS$0

US$96,000 of exposure against nil tax. That asymmetry is why the disclosure routes exist and why the sequence of filings matters more than the arithmetic — filed in the right order under the right route, the penalty position can be very different from this. The shape of that result holds; the size of it depends entirely on your own numbers and dates.

An illustration, not a client file. The sums are chosen for legibility and the thresholds are stated for the example alone — nothing reaches a filing until it has been confirmed at source for your own year.

What working with us looks like

  1. 1We start with the chronology: dates, countries, and what has already been filed
  2. 2You get the scope and the fee in writing before we touch anything
  3. 3The work is prepared and reviewed by a named person, not a queue
  4. 4Nothing is filed until you have read it

The fixed fee

The commercial part is deliberately boring. One fixed fee for a written scope, agreed up front in writing — which is what lets us tell you honestly when IRS voluntary disclosure practice is smaller than you feared. Comparable engagements and their fixed fees are set out on the pricing pages.

  • Nothing is filed until you have read it.
  • Rated 5.0 out of 5 stars on Google, on a profile open for you to read.
  • Your existing accountant keeps the domestic file; we take the cross-border piece, with the boundary in writing.

How to get this moving

Describe the situation in your own words; translating it into forms is our job. The fastest start is a short call and three things: what happened, when it happened, and which countries are involved. Everything else we can ask for as it comes up.

Read and approved for the 2025 and 2026 filing seasons by Udit Gupta, Cross-Border Tax Expert, Legal Quotient Consultants. General information, not advice for your circumstances — call our 24-hour helpline to discuss your own position.

IRS streamlined foreign offshore procedures, in practice

If you came here for IRS streamlined foreign offshore procedures, this is where it is dealt with. The subject is IRS voluntary disclosure practice, and the page covers who it reaches, what then has to be filed, and what we charge to do the work.

Where the conduct was not non-willful, the streamlined programmes are unavailable and the voluntary disclosure practice is the route that addresses criminal exposure.

From first contact to filed return

  1. Send what you already have

    Slips, statements, prior returns — in any order. We list what is still needed after reading them.

  2. A fee agreed in writing

    Quoted from those documents, before the work starts, and it does not move once you accept it.

  3. Each side drafted against the other

    The returns are built together rather than in sequence, so relief is claimed once and in the right country.

  4. You approve before it is filed

    The finished return comes to you first. Nothing is submitted on your behalf unseen.

The difference a dedicated cross-border team makes

Factor Legal Quotient Hourly billing model
Pricing A fixed fee, agreed in writing before work starts Hourly, billed as incurred
Experience 15+ years of cross-border work, 18,000+ clients Varies by file
Both sides of the border Prepared together by one team, so relief is claimed exactly once One country at a time, reconciled later
Who reviews it A named practitioner, published on the page Whoever the queue reaches
Where the work happens Our offices in India, the USA, Canada and the UAE Whichever single office you can travel to

The vocabulary this page leans on

Deemed dividend
An amount treated as a distribution although not declared as one — commonly a shareholder benefit, a loan or a secondary transfer-pricing adjustment.
Newcomer
Someone who has become resident during the year. Property held on arrival is generally treated as acquired at that day's value, which is why arrival-value evidence is worth keeping.
Cost contribution arrangement
An arrangement in which participants share the cost and risk of developing something in exchange for a share of the benefit.
Part-year resident
Someone resident for only part of a tax year. Worldwide income is reported for the resident period and source income for the rest, with credits prorated to the resident portion.
IRS voluntary disclosure practice: The practitioner's note

It runs in stages, beginning with a pre-clearance request, and it produces a defined civil penalty framework rather than penalty relief.

However the file develops, three things stay fixed: a written scope and fee before work begins, a named practitioner reviewing the result, and your approval before anything is filed.

Fixed fees around IRS voluntary disclosure practice

This route exists because criminal exposure does, so the analysis sits with counsel and we work to their instructions; that relationship shapes the engagement more than the paperwork does. The civil penalty framework it produces has to be computed on peak balances, account by account, and heavy account histories are quoted for separately.

CRA voluntary disclosure package

$349fixed, before work starts

Covers: The disclosure application with the corrected filings, a documented chronology of how the failure arose, and representation through to the CRA's decision.

What makes it bigger: Whether income as well as reporting was missed. A late information return is one conversation; unreported income across several years is another.

See this fee page

Streamlined catch-up — 3 years + 6 FBARs

$449fixed, before work starts

Covers: The full streamlined submission: the back returns, the account reports for the whole period, and the non-willfulness certification that is the substance of the application.

What makes it bigger: The number of years and the state of the records. The filings are mechanical; reconstructing account histories and building the chronology is what takes the time.

See this fee page

FBAR & Form 8938 disclosure

$449fixed, before work starts

Covers: Both US foreign-asset reports prepared from one account and asset list, with the different contents each of them requires, and reconciled to the return they accompany.

What makes it bigger: Accounts you do not think of as yours. Signature authority over an employer's or a relative's account is inside one report and often outside the other, and finding them takes longer than filing them.

See this fee page

Why choose Legal Quotient for IRS voluntary disclosure practice

One team, not two firms billing separately

You are not the go-between for two sets of advisers with two sets of assumptions. One engagement covers each country the file touches.

Every figure on a page is traceable

Where a rate or a threshold appears in our writing it names the tax year it belongs to. Where it could not be confirmed, the page describes the mechanism and quotes no number.

4 global offices

Meet us in person in India, the USA, Canada and the UAE, or send everything through the secure portal — the same process either way.

The reporting penalties get named early

The heaviest exposure on a cross-border file is usually a disclosure form, not the tax. We identify which ones apply before a deadline turns into a penalty.

Two of the firm’s advisers at a desk in the Delhi office

IRS voluntary disclosure practice — the four phases

Step 1

The opening call

A call to the 24-hour helpline to find out whether this is a filing or a project

Step 2

Scope in writing

A fixed fee for a written scope — re-quoted if the scope changes, never invoiced silently

Step 3

Prepared and checked

Preparation against the evidence, with the positions documented as we go

Step 4

Filed, then supported

Your approval, then the filing — in that order

Two of the firm’s advisers at the glass desk in the Delhi office

From first document to filed return

  • Step 1: Share your documents – A secure upload link arrives after the first call — send files in any state.
  • Step 2: A written fixed fee – The quote is fixed from what you send; it does not move once accepted.
  • Step 3: Preparation, both sides at once – The returns are drafted together, reconciled line against line.
  • Step 4: Approve, then file – Nothing is filed until you have seen it and approved it.

Quoted up front, in writing.

Contact Us 24-hour helpline +1 (416) 619-0068

Where to go next

Browse sideways: the pages below answer the neighbouring questions.

The work we do for clients like this

Tax on permanent residency Its own page: tax on permanent residency — mechanism, deadlines and published fees.
SEZ, GIFT City and tax holidays Everything on SEZ, gift city and tax holidays, at the same depth as this page.
Form NR74 — determination of residency on entering NR74 determination of residency entering — the guide, the FAQ and the fixed fee.
Employee vs contractor — both countries The full guide to employee vs contractor — both countries, with the fee fixed before any work starts.
Indian withholding on software payments Its own page: Indian withholding on software payments — mechanism, deadlines and published fees.
Foreign-owned Canadian company — filings Everything on foreign-owned Canadian company filings, at the same depth as this page.
Form 2350 — extension for citizens abroad Form 2350 extension abroad — the guide, the FAQ and the fixed fee.
Dividends, interest and royalties — the treaty articles The full guide to dividends interest royalties treaty articles, with the fee fixed before any work starts.
Limitation on benefits — the treaty test Its own page: limitation on benefits treaty — mechanism, deadlines and published fees.

Clients who arrive with this exact page

Oil & gas rotational workers — what we charge Its own page: oil & gas rotational workers what we charge — mechanism, deadlines and published fees.
Tax for construction workers abroad Everything on construction workers abroad tax, at the same depth as this page.
Technology & SaaS cross-border tax Technology & saas cross border tax — the guide, the FAQ and the fixed fee.
Management consultants — what you owe in each country The full guide to management consultants what you owe in each country, with the fee fixed before any work starts.
Shopify & DTC brands cross-border tax Its own page: shopify & dtc brands cross border tax — mechanism, deadlines and published fees.
Tax for models Everything on models tax, at the same depth as this page.
Tax for aid & ngo workers Aid & ngo workers tax — the guide, the FAQ and the fixed fee.
Amazon FBA sellers — what we charge The full guide to amazon fba sellers what we charge, with the fee fixed before any work starts.
Tax for actors & film crew Its own page: actors & film crew tax — mechanism, deadlines and published fees.

Countries and corridors this work reaches

Sri Lanka tax for expats — country guide Its own page: Sri Lanka tax for expats — mechanism, deadlines and published fees.
Costa Rica tax for expats — country guide Everything on Costa Rica tax for expats, at the same depth as this page.
Netherlands tax for expats — country guide Netherlands tax for expats — the guide, the FAQ and the fixed fee.
Finland tax for expats — country guide The full guide to Finland tax for expats, with the fee fixed before any work starts.
Uganda tax for expats — country guide Its own page: uganda tax for expats — mechanism, deadlines and published fees.
Colombia tax for expats — country guide Everything on Colombia tax for expats, at the same depth as this page.
Slovenia tax for expats — country guide Slovenia tax for expats — the guide, the FAQ and the fixed fee.
Latvia tax for expats — country guide The full guide to latvia tax for expats, with the fee fixed before any work starts.
Canada–Philippines tax corridor Its own page: Canada Philippines tax — mechanism, deadlines and published fees.

The people on your file

Five named practitioners, each with the part of a cross-border file they carry. Every page on this site says who reviewed it, and the reviewer is one of these people rather than an unnamed team.

Udit Gupta

Udit Gupta

Cross-Border Tax Expert

CA (ICAI), In-Depth Tax Trained

Reviews and signs off the practice's cross-border positions, and carries final responsibility for the treaty analysis on every file that leaves the office.

Abhinav Gupta

Abhinav Gupta

Canada Tax / International Tax

Canada Tax, International Tax, Cross-Border Tax, Transfer Pricing

Canadian returns with foreign income, non-resident filings, and the transfer-pricing documentation that runs alongside intercompany work.

Raghav Gupta

Raghav Gupta

International Tax

International Tax, Transfer Pricing Specialist

Benchmarking, method selection and the local-file and master-file sets that support a group's pricing policy under examination.

Anmol Mittal

Anmol Mittal

Canada and US tax

CPA Canada, CPA USA, CA (ICAI)

Files that have to be right on both sides of the border at once — dual filings, streamlined catch-ups, and the foreign tax credit reconciliation between them.

Vinayak Indolia

Vinayak Indolia

CFO advisory

CPA, CA. Fractional CFO and Senior Advisory Specialist

Groups that need the tax position and the finance function to agree: structure reviews, intercompany policy, and the reporting a board can act on.

Meet the whole team

Cross-border situations we are engaged for

Case study 1

Pre-clearance filed first while the return work was deliberately held

The client wanted every year prepared at once so that a complete package could go in together. We advised against it. The practice runs in stages, and until the earlier stage has been answered the shape of the submission is not settled. Counsel made the pre-clearance request while we scoped the reconstruction without filing anything. The engagement produced a sequence matching the practice rather than cutting across it, and returns prepared once, against a confirmed route, instead of twice.

Case study 2

Matter moved to counsel after the facts ruled out non-willfulness

The client came to us expecting a streamlined submission. Reading the file, the account histories and the correspondence, the conduct did not fit a non-willful account, and signing a certification to that effect would have made the position worse rather than better. We said so, stopped the work, and referred the matter to counsel before anything was prepared. The engagement produced no filing at all in its first phase, which was the correct outcome, and a written note of the facts that had driven the conclusion.

Case study 3

Records assembled in stages to match the disclosure timetable

Bank records spanning several jurisdictions had to be requested and some institutions were slow. Rather than wait for everything before starting, we worked to the practice's own sequence, assembling what each stage required as it was reached, and keeping a schedule of what remained outstanding and who had been chased. Counsel could see at any point what the submission rested on. The engagement produced a documented record of the reconstruction alongside the filings themselves.

Case study 4

Business income abroad traced through a structure before any filing

Income had been received through a company and a nominee arrangement abroad, and who had actually earned what was not obvious from the statements. We traced the flows through the structure, established the beneficial position year by year, and marked clearly where the analysis rested on inference rather than on documents. That distinction mattered, because a disclosure describes conduct and the description has to be accurate. The engagement produced an income analysis counsel could rely on when settling the terms of the submission.

Case study 5

Second opinion that stopped a streamlined submission being made

A package was drafted and ready for signature when the client asked for a review. The certification asserted a misunderstanding that the surrounding correspondence contradicted on its face. We set out the contradiction, explained what filing it anyway would put on the record, and the submission was not made. The client took the question to counsel and the matter proceeded on a different footing. The engagement produced a written review of the draft and a decision taken before, rather than after, a signature.

Case study 6

Civil penalty framework explained before the client decided to proceed

The client's central question was practical rather than technical: what does this route actually leave me with. We set out how the framework operates, what it is computed on, and where the discretion lies, without putting numbers on a case whose facts were still being established. Counsel added the criminal analysis. The engagement produced a written explanation the client could take away and consider, and a decision to proceed taken with the mechanics understood rather than assumed.

Case study 7

Years Filed Quietly, and What That Cost

Posting missing returns without taking a view on the route gives up the certification-based protection and can itself be read as an indicator. The first task on these files is mapping which years remain eligible for which route.

Read how this one runs
Case study 8

A Family Trust Abroad With Reporting on Both Sides

A trust settled in one country and a beneficiary living in another produces reporting for the trust, the settlor and the beneficiary, on different forms and different dates. The engagement maps who files what before anything is prepared.

Read how this one runs

All case studies — every published engagement in one place.

Delivery, coverage and how we work

Browse sideways: the pages below answer the neighbouring questions.

Where the work is delivered

More coverage detail

Core International & Cross-Border Tax Services

International Tax Planning & Advisory

Strategy and compliance for income, assets and families spread across borders.

Treaty residency & tie-breaker
FATCA reporting (Form 8938)
Foreign tax credit (Form 1116)
Multi-country filing calendar
Real estate holding structures
International tax planning
Pre-immigration tax planning
Family office structures
One coordinating team: filings on every side of the border are sequenced so treaty relief and foreign tax credits are claimed once — and in the right country.

U.S. & Cross-Border Tax Returns

Form 1040 from abroad
US state non-resident returns
FBAR (FinCEN 114) filing
Form 5472 — foreign-owned US corp
FIRPTA withholding (Form 8288)
US estate tax exposure
IRS streamlined foreign offshore
PFIC reporting (Form 8621)
Dual filers: U.S. citizens in Canada and Canadians with U.S. income run two parallel systems — we prepare both, in the right order, every year.

Expat & Emigration Tax

Departure tax leaving Canada
T1161 properties on emigration
Residency planning
Step-up in cost base on arrival
Split-year residency
Employment income under a treaty
Social security totalization
Returning to Canada after years abroad
The move year is its own project: the elections and valuations filed that year decide the next decade of both countries’ returns.

Non-Resident Canadian Tax

Section 216 rental return
NR4 & NR6 withholding
Section 217 pension return
Section 116 clearance certificate
Regulation 105 waiver
Non-resident employment income
Taxable Canadian property
Part XIII withholding review
Default withholding is 25% of gross: elective returns routinely turn over-withheld rent and pensions into refunds.

Transfer Pricing & BEPS

s.247 contemporaneous documentation
Functional & risk analysis
Benchmarking study
Intercompany agreements
Country-by-country report
BEPS & Pillar Two
Permanent establishment risk
TP audit defence file
Documentation prepared with the return is the cheapest insurance in international tax; reconstructing it during an audit is the most expensive.

Cross-Border Estates & Trusts

Cross-border wills
US estate tax for non-resident aliens
Terminal return & clearance certificate
Non-resident trusts (s.94)
T1141 & T1142 trust reporting
Inheriting property abroad
Graduated rate estates
Post-mortem planning & pipeline
Wills drafted for one country routinely misfire in the other — deemed disposition here, estate tax there, credits in between.

Cross-Border Corporate Tax

Entity selection across borders
Business profits & PE
Intercompany loans & thin cap
Paying dividends to a foreign parent
Global mobility & day tracking
Debt vs equity funding
Branch or subsidiary
Cross-border M&A due diligence
Expansion raises the same four questions every time — entity, PE, repatriation, payroll. We answer them before the tax authorities do.

India Tax for NRIs & Returning Residents

NRI residency day tests
NRE, NRO & FCNR accounts
TDS on property (s.195)
Lower or nil TDS certificate
Repatriating sale proceeds
Capital gains on Indian shares
India–Canada DTAA
ITR-2 for NRIs
The deduction is taken on the sale price, not the gain — which is why an NRI property sale strands cash unless the certificate is applied for before closing.

Canadian Tax with a Foreign Element

T1135 foreign property
T1134 foreign affiliates
Departure tax
Newcomer's first return
Returning to Canada
Split-year residency
US citizens in Canada
Canada–US corridor
Residency is decided on facts, not on a form — and the year you arrive or leave is the one where the largest amounts turn on the smallest details.

UAE Tax for Expats & Their Home Country

Expat tax in the UAE
Moving to the UAE
Moving back from the UAE
UAE property purchases
Retiring in the UAE
Canada–UAE corridor
India–UAE DTAA
US–UAE corridor
A zero-tax country is only half the answer — the question that decides the bill is whether the country you came from still treats you as resident.

Industries & Client Types We Serve Worldwide

Global E-commerce & Marketplaces
Technology & SaaS
Professional Services Firms
Cross-Border Real Estate
Importers, Exporters & Manufacturers
Athletes, Artists & Entertainers
Remote Workers & Digital Nomads
Investment Funds & Holding Companies

Global E-commerce & Marketplaces

  • Foreign VAT / GST / sales tax registrations
  • Marketplace withholding reviews
  • Inventory nexus & PE analysis
  • Multi-currency books reconciled
Explore E-commerce & Marketplaces

Technology & SaaS

  • Cross-border revenue sourcing & withholding
  • IP structuring with real substance
  • Equity for cross-border teams
  • U.S. expansion: entity & PE setup
Explore Technology & SaaS

Cross-Border Real Estate

Foreign property income and sales are taxed in both countries by default; Section 216, FIRPTA and treaty credits are the standing toolkit.

Property is taxed where it sits, which is the one rule no treaty overrides. What the treaty does decide is the credit, the rate on the rent and what happens on the sale — and the clearance certificate on a disposition is applied for before closing, not after the buyer has already held the money back.

  • Section 216 rental returns
  • FIRPTA withholding recovery
  • Section 116 clearance
  • Treaty credit optimization
Explore Real Estate

Importers, Exporters & Manufacturers

  • Transfer pricing documentation (s.247)
  • Customs value vs transfer price
  • Foreign affiliate reporting (T1134)
  • Country-by-country reporting
Explore Trade & Manufacturing

Athletes, Artists & Entertainers

  • Reg 105 & U.S. CWA agreements
  • Multi-state & country calendars
  • Touring income allocation
  • Royalty & image-rights withholding
Explore Athletes & Entertainers

Remote Workers & Digital Nomads

  • Residency analysis before moving
  • Employer payroll exposure
  • Totalization & social security
  • Foreign tax credits
Explore Remote Workers

Investment Funds & Holding Companies

  • Treaty access & PPT reviews
  • FAPI & surplus computations
  • Withholding-efficient routing
  • Governance & substance
Explore Funds & Holdcos

IRS voluntary disclosure practice — questions we are asked

IRS voluntary disclosure practice — is this a do-it-yourself job?

Some of it, yes — and we will say so on the call if that is the honest answer. The parts that are worth paying for are the ones where a missed election, a missed deadline or an unverified threshold costs more than the fee: it runs in stages, beginning with a pre-clearance request, and it produces a defined civil penalty framework rather than penalty relief.

What if I have already filed and got it wrong?

That is a common starting point. We re-derive the position, identify whether an amendment or a disclosure route is the right vehicle, and tell you which one preserves the relief that is still available. The order matters more than the speed.

How long will it take?

It depends on the documents rather than on us. Once the pack is complete most filings turn around inside a fortnight; anything that needs a certificate from a tax authority runs on that authority's timetable, which we tell you at the start rather than at the end.

What is the difference between streamlined and the voluntary disclosure practice?

Streamlined is for taxpayers whose failure to report was non-willful. Where the conduct was not non-willful, the streamlined programmes are simply unavailable, and the voluntary disclosure practice is the route that addresses criminal exposure. The two also work differently. Streamlined is a package you prepare and file. Voluntary disclosure runs in stages, beginning with a pre-clearance request, and it produces a defined civil penalty framework rather than penalty relief. Choosing between them is not a matter of preference: it follows from the facts, which is why the facts are examined first.

Do I need a lawyer for an IRS voluntary disclosure?

The practice exists because of criminal exposure, so the analysis belongs with counsel before anything is filed. That is not a formality. What you say about your own conduct in a disclosure is a statement on the record, and the privilege position around how it was arrived at matters. Our role sits alongside counsel rather than in place of it: we do the reconstruction, the returns and the reporting, while the question of whether to disclose and on what terms is taken with the lawyer. We will say plainly when a matter needs counsel before it needs an accountant.

What is pre-clearance and what happens after it?

Pre-clearance is the first stage. It is a request made before any disclosure is submitted, asking whether you are eligible to use the practice at all, and it is answered before the substantive material goes in. Treating it as a formality is a mistake, because the sequence is the protection: the stages exist so that eligibility is settled before the detailed account of the conduct is filed. In practice this shapes the whole timetable, and it is why return preparation is often deliberately held back until the earlier stage has been answered.

Does a voluntary disclosure protect me from prosecution?

Criminal exposure is the reason the practice exists, and addressing that exposure is what it is for. It is not immunity, and nobody can responsibly tell you otherwise, which is exactly why the decision is taken with counsel rather than with an accountant. What the practice does offer is a defined route and a defined civil penalty framework, in place of the uncertainty of waiting to be found. Whether that route suits your facts is the question to answer first, and it is answered on the facts rather than on the amounts.

Can I use voluntary disclosure if I already filed a streamlined submission?

It is a difficult position, and it needs to be looked at before anything further is filed. A streamlined submission includes a signed certification that the conduct was non-willful. Where the facts do not support that certification, the document already on the record is part of the problem, and the disclosure analysis has to take it into account rather than work around it. This is one of the clearest cases for counsel being involved from the outset. Bring everything that was filed, including the drafts and the correspondence around them.

Will voluntary disclosure reduce the penalties I would otherwise face?

That is the wrong expectation to bring to it. The practice produces a defined civil penalty framework rather than penalty relief, and the benefit is that the framework is known and the exposure is bounded, not that the amounts are small. Compared with the streamlined programmes, which are built around relief for non-willful conduct, this is a different bargain for a different set of facts. If your facts support non-willfulness, streamlined is the route to examine. If they do not, the comparison that matters is with the position you are in now.

Do dual citizens have to file US taxes if they live abroad?

Yes. US filing follows citizenship, not residence or where the income arose, and the obligation continues for as long as the citizenship does. Two further obligations travel with it and are keyed to account balances rather than income, so they can apply in a year with no US tax at all: the foreign bank account report to FinCEN, and the specified foreign asset statement with the return. Most people who discover a problem discover it there. See two returns as a dual citizen.

What is the difference between FBAR and Form 8938?

They overlap but are not the same report. The FBAR goes to FinCEN and covers foreign financial *accounts*; Form 8938 goes to the IRS with the return and covers a wider class of specified foreign financial *assets*, with thresholds that vary by filing status and whether you live abroad. Many people must file both for the same accounts, and satisfying one does nothing for the other. See filing both.

Tax terms explained

Grantor trustForm 3520Customs valuationClubbing of incomeRNORNon-discrimination articleWithholding certificateMutual agreement procedureTerminal returnBona fide residence testCloser connectionThin capitalisationReviewer sign-offFaceless assessment Browse the full A–Z glossary

Related pages

The rest of this section

All catch-up & disputesCRA Voluntary Disclosures Program — offshore and unreported incomeSecond opinion on a filed returnIndian scrutiny assessment (s.143(2))Taxpayer relief — penalties & interestLate T1135 — penalty reliefTax Court of Canada appeals

Adjacent services

Form RC268 — US plan contributions (cross-border)Form 7004 — business extensionForm 1099-NEC — for foreign contractorsForm T1244 — election to defer departure taxForm RC269 — foreign plan contributionsForm 1120 — US corporation return and treaty claims

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