Since 2009, in the days of the earliest versions of the present day Offshore Voluntary Disclosure Program (OVDP) Tim Kelly and Kevin Rego have been involved in bringing taxpayers "in from the cold." Often through very little fault of their own, taxpayers found themselves on the wrong end of the law, facing prosecution by the United States Department of Justice because of foreign banks accounts where they had funds or assets depositied.

Many were ignorant as they honestly believed they were doing nothing wrong by not reporting offshore bank accounts. Many were victims of circumstance, such as those who inherited offshore accounts and were not aware of the compliance requirements attached to foreign holdings. Others fell prey to offshore investment gurus, who convinced their victims that through elaborate multi-national structures American tax liability could be legitimately avoided.

And yes, there were those taxpayers (or, as it were, NON taxpayers) who were just too clever for their own good. They knew better, yet still sequestered money away from the eyes of Uncle Sam. For a long time it appeared the gravy train of having your Swiss Bank account and spending it too was never going to end. But the combined forces of technology and government's insatiable appetite for tax revenue proved a juggernaut too powerful to overcome. As the cliche goes, you can run but you can't hide, and neither can your money.

Our attorneys have traveled extensively throughout all six populated continents helping American citizens come back into the system as comfortably as their circumstances might allow. Some cases are easier than others to be sure, but resolution is always possible.

Currently the IRS has four different programs to assist taxpayers with coming into compliance. The two most common programs which Tim handles are the Streamlined Offshore Domestic Procedures (SDOP) and the Streamlined Foreign Offshore Procedurs (SFOP).

Contact Tim at, or Kevin at to discuss the current status of the OVDP or the streamlined procedurs to understandand how these procedures amy be used to lower your anxiety and allow you to sleep with both eyes closed. Even if you live overseas, your confidential communications concerning the United States government are only safe with an American attorney. Because there are potential criminal liability implications, CPA's or other tax professionals do not possess the ability to shield privileged communications from the government.