Reasonable cause letters
If you are not currently in compliance with the U.S. tax system, any attempt to come into compliance will raise the “Spectre” of penalties. Most of these penalties can be abated if you can demonstrate that you had “reasonable cause” for the omission. What “reasonable cause” means to the IRS is NOT necessarily what it would mean to the average person. Most people would regard not knowing about an FBAR, Form 5471, Form 3520, etc. to constitute “reasonable cause”. Although lack of knowledge is a factor in determining “reasonable cause”, it is NOT (in most cases) sufficient. Is it “reasonable” that you did not know of the requirement?
Suffice it to say that you will need “reasonable cause” letters that are well considered, well written and reflect the law of “reasonable cause”.
We will work with you on developing your “reasonable cause” letter(s).