Foreign Bank Accounts and Assets Reporting Compliance

Individuals who have not disclosed their foreign bank accounts and foreign financial assets face significant civil penalties and even criminal prosecution by the IRS. The Law Offices of Sun J. Chung can help individuals who have not reported their offshore accounts or income earned from offshore accounts come clean with the IRS and minimize exposure to the devastating penalties and criminal investigation.

To help individuals become compliant of their offshore reporting requirements, the IRS has implemented several disclosure programs and options, notably the Offshore Voluntary Disclosure Program and the Streamlined Filing Compliance Procedures, which permits individuals to come forward voluntarily and permanently resolve their tax issues.

In order to participate in the voluntary disclosure program, individuals must come forward before they are notified by the IRS regarding their undisclosed foreign accounts or assets. If an individual is currently under examination by the IRS or has been contacted by the IRS regarding his undisclosed foreign accounts or assets, he will not be eligible to take advantage of the voluntary disclosure program. Contact us today for a free case evaluation and an explanation of all options available to you under the disclosure programs.

Offer in Compromise (OIC)

An Offer-in-Compromise (“OIC”) is an agreement between the IRS and an individual to settle a tax debt for less than the amount owed. If you are in a financial position where you are unable to fully pay the tax debt, you may be able to resolve your tax debt for far less than the amount owed. Once accepted, an OIC allows an individual to wipe the tax slate clean and truly have a fresh start. Call us today for a free evaluation of your case.

Tax Litigation

If you have gone through an IRS audit and are unhappy with the results, you can have your case re-heard in Tax Court. You can pursue your case in Tax Court without first having to pay the tax the IRS claims you owe. Don’t throw in the towel without first pursuing all options available to you.

Penalty Abatement

Among the numerous IRS and FTB penalty provisions, Taxpayers are most often hit with the Failure-to-File, Failure-to-Pay, and accuracy related penalties. These penalties can often be substantial and can have devastating consequences to you financially. Fortunately, if certain requirements are met, the IRS and FTB may allow for an abatement or refund of the penalties assessed. Let us represent you and present your case in the best possible light to have these penalties waived.

Levy & Wage Garnishments

The IRS and FTB will often use aggressive tactics in collecting the tax owed—this includes wage garnishments and bank levies. Once issued, your employer and/or bank must comply to the IRS’ or FTB’s wage garnishment or bank levy order. Let us help you before a levy or garnishment is issued. If you have already been hit with a bank levy or wage garnishment, we can help you get those released as we have successfully done for our clients.


If you are unhappy with the results of your IRS audit, you can have your case re-evaluated in the IRS’ Office of Appeals. An Appeals Officer is usually more skilled an experienced in the tax laws and is given more discretionary powers to resolve a tax debt with an individual. Together, we will develop the best strategy to achieve the most favorable outcome in your case. Let us help you today!