Streamlined Filing Compliance Procedures: IRS Foreign and Domestic Amnesty Programs

Course Details
- smart_display Format
On-Demand
- signal_cellular_alt Difficulty Level
Intermediate
- work Practice Area
Tax Preparer
- event Date
Tuesday, July 26, 2022
- schedule Time
1:00 p.m. ET./10:00 a.m. PT
- timer Program Length
110 minutes
-
BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.
-
BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
This webinar will guide international tax advisers through streamlined compliance programs offered by the IRS to bring taxpayers up to date on their tax and foreign reporting obligations. Our authoritative panel will explain eligibility requirements and required documentation as well as offer advice to facilitate acceptance and resolution of past noncompliance.
Faculty

Mr. Warshaw has nearly 40 years of experience as a U. S. estate planning and tax lawyer. He currently represents U. S. and non-U. S. high net worth individuals, families and companies on a wide range of personal and business tax matters, especially in connection with cross-border income and estate tax planning and compliance in the U. S. Mr. Warshaw is admitted to practice in the Commonwealth of Massachusetts. He regularly advises non-U. S. clients on structuring inbound pre-immigration tax strategies including basis step-up in legacy assets, avoiding the U. S. CFC and PFIC anti-deferral tax regimes, optimizing use of foreign tax credits, minimizing green card status as well as advising on and drafting of “drop-off trusts.” Mr. Warshaw also advises long-term green card holders and U. S. citizens on planning to minimize their U. S. exit tax through gift programs, managing equity compensation and by drafting “expatriation” trusts and considerations of a change of domicile outside the U. S. He has also counseled clients in complying with their U. S. tax filing obligations by engaging accountants and bringing such taxpayers into compliance with their numerous U. S. international tax reporting requirements. Mr. Warshaw has also advised on the U. S. international tax aspects of cryptocurrency, including how to become U. S. tax compliant and how to mitigate U. S. tax implications prior to and following renouncing U. S. citizenship.

Ms. Castellanos is the CEO and Founder of Global Taxes LLC. She provides personalized U.S. tax advisory and compliance services to high net worth families and their advisors. Ms. Castellanos has more than 20 years of experience. Prior to forming Global Taxes, she founded and oversaw operations at a boutique tax firm, worked at a prestigious global law firm and CPA firm. Ms. Castellanos specializes in U.S. tax planning and compliance for non-U.S. families with global wealth and asset protection structures which include non-U.S. trusts, estates and foundations that have a U.S. connection. She also specializes in foreign investment in U.S. real estate property, and other U.S. assets, pre-immigration tax planning, U.S. expatriation matters, U.S. persons in receipt of foreign gifts and inheritances, foreign accounts and assets compliance, offshore voluntary disclosures/tax amnesties, FATCA registration, and foreign companies wanting to do business in the U.S. Ms. Castellanos is fluent in Spanish and has a working knowledge of Portuguese. She is an active full member of the Society of Trusts & Estates Practitioners (STEP), the New York State Society of Certified Public Accountants (NYSSCPAs), the American Institute of Certified Public Accountants (AICPA), the International Fiscal Association (IFA), a member of Clarkson Hyde Global, a world-wide association of accountants, auditors, tax specialists and business advisors and the International Advisory Experts (IAE). Ms. Castellanos has chaired the annual NYSSCPA International Tax Conference for 3 years in a row. Distinctly, in 2020, she was awarded with a prestigious NYSSCPA Forty Under 40 Award. Ms. Castellanos was selected as someone that has notable skills and is visibly making a difference in the accounting profession. She has also been recognized as a leading expert for Tax advice and she has been invited to join Advisory Excellence, as their exclusively recommended tax expert in the USA.
In 2021, Ms. Castellanos was the Gold Winner of Citywealth's 2021 Powerwomen Awards in the category USA - Woman of the Year - Business Growth (Boutique).
In 2022, she was the Silver Winner of Citywealth's 2022 Powerwomen Awards in the category USA - Woman of the Year - Business Growth (Boutique).
Global Taxes and Ms. Castellanos received a nomination for the Magic Circle Awards 2022 edition. For Global Taxes as Accountancy Firm of the year - US and for Alicea Castellanos as the Accountant of the year category.
She was selected by Citywealth as one of the Top 10 Accountants of 2021 serving the Ultra High-Net-Worth Individual (UHNW) segment of the market. The members of the list were selected through thorough independent research undertaken by the editorial team who took into consideration both peer and client feedback.
Furthermore, Ms. Castellanos is currently listed in the Global Elite Directory 2022-23, which is an annual exclusive directory of the world's elite lawyers and outstanding wealth advisors advising ultra-high net-worth clients.
Description
For taxpayers behind on their income tax and information return filing obligations, the IRS offers streamlined compliance programs. The requirements are stringent, but the benefits include substantial penalty relief and peace of mind for taxpayers seeking amnesty. The Streamlined Foreign Offshore Procedures (SFOP) provide relief for nonresidents, including abatement of penalties.
The Streamlined Domestic Offshore Procedures (SDOP) for residents include a five percent Title 26 miscellaneous offshore penalty. Both programs require that taxpayers certify that their noncompliance was nonwillful. Prior tax returns and additional foreign reports, including Forms 8938, 3520, 5471, and the FBAR, are among the voluminous required submissions for both the SFOP and SDOP.
Some taxpayers chose to file and expatriate. The transition tax under Section 965 must be calculated and paid. Practitioners can provide a valuable service by assisting noncompliant multinational taxpayers with the streamlined compliance procedures. Understanding how to avoid common errors and expedite the acceptance of these agreements is critical.
Listen as our panel of international tax experts guides you through SFOP and SDOP to help taxpayers become compliant.
Outline
- Streamlined Foreign Offshore Procedures (SFOP)
- Streamlined Domestic Offshore Procedures (SDOP)
- Required submissions
- Income tax returns
- Information returns
- Certification statements
- Expatriation and Section 965 transition tax
- Handling an audit
- Avoiding common errors
- Alternatives to SFOP and SDOP
Benefits
The panel will cover these and other critical issues:
- What is considered nonwillful noncompliance under the streamlined compliance programs?
- How the five percent Title 26 penalty is calculated for the SDOP
- Which taxpayers are eligible for the SFOP?
- What common errors should practitioners avoid when filing for relief under the streamlined compliance programs?
NASBA Details
Learning Objectives
After completing this course, you will be able to:
- Identify taxpayers eligible for SFOP
- Determine the penalty required under Title 26 for SDOP
- Ascertain which foreign returns are required to be filed under the streamlined compliance procedures
- Decide when a taxpayer might benefit from SDOP
- Field of Study: Taxes
- Level of Knowledge: Intermediate
- Advance Preparation: None
- Teaching Method: Seminar/Lecture
- Delivery Method: Group-Internet (via computer)
- Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
- Prerequisite: Three years+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of international taxation including residency determination, foreign entity classifications, application of treaty benefits, as well as GILTI, Subpart F, and the related Section 250 deductions.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
Unlimited access to premium CLE courses:
- Annual access
- Available live and on-demand
- Best for attorneys and legal professionals
Unlimited access to premium CPE courses.:
- Annual access
- Available live and on-demand
- Best for CPAs and tax professionals
Unlimited access to premium CLE, CPE, Professional Skills and Practice-Ready courses.:
- Annual access
- Available live and on-demand
- Best for legal, accounting, and tax professionals
Related Courses

Mastering Form 5472: Filing Requirements for Foreign Individuals, LLCs, and Companies
Friday, May 30, 2025
1:00 p.m. ET./10:00 a.m. PT

Charitable Remainder Trusts: Utilizing CRATs and CRUTs to Minimize Income and Transfer Tax, SECURE 2.0 QCDs
Thursday, May 29, 2025
1:00 p.m. ET./10:00 a.m. PT

LLC and Partnership Purchases: Entity Interests vs. Asset Sales, Basis Adjustments, Elections, Tax Reporting
Thursday, May 15, 2025
1:00 PM E.T.
Recommended Resources
How CPE Can Bridge the Gap Between What You Know and What You Need to Know
- Career Advancement