The purpose of this primer is to briefly outline key considerations for participation in the US Internal Revenue Service (‘’IRS’’) Streamlined Foreign Offshore Procedures, a compliance program available to U.S. taxpayers residing outside the United States. Many US taxpayers living abroad have been unaware of their US tax filing obligations and for many of these, the Streamlined Foreign Offshore Procedures is the best way of resolving outstanding tax non-compliance.

As a US tax accounting firm in Switzerland, we are often asked whether tax paid to Switzerland under a “forfait” or “pauschal” ruling (“forfait tax”) is creditable against the US income tax under the US foreign tax credit provisions. The US foreign tax credit is a dollar-for-dollar credit with respect to foreign taxes paid and is intended to alleviate the burden of simultaneous taxation by two countries on the same income.