Former IRS attorneys who successfully resolve tax matters pertaining to Santander bank accounts, including IRS Voluntary Disclosure, the Foreign Accounts Tax Compliance Act (FATCA) and FATCA letters, the Offshore Voluntary Disclosure Program (OVDP) and the Streamlined Offshore Disclosure Program


Known as Sovereign Bank until a rebranding in 2013, Santander Bank, N.A. is a Boston-based subsidiary of the Santander Group. Today, the bank offers services that include retail banking, mortgages, corporate banking, cash management, credit card, capital markets, trust and wealth management, and insurance. 

If you’ve been contacted by the Internal Revenue Service (IRS) regarding your offshore bank account at Santander, you may be overwhelmed by the road that lies ahead. In recent years, the U.S. government has stepped up its enforcement of offshore account disclosure. This may explain why you’ve had a bank account with Santander for years, but are only just now being notified of a government investigation into your assets. 

Since July 1, 2014, when the Foreign Accounts Tax Compliance Act (FATCA) legislation went into effect, the government has frozen and cancelled countless foreign accounts. In order to move forward with your assets, you must prove that you have complied with FATCA filing regulations. It’s important to note that FATCA letters may come from either the financial institution or the government. When letters are sent directly from the IRS or Department of Justice (DOJ), it is very important that you contact a tax lawyer immediately because a severe civil or criminal investigation has already been opened. Regardless of who sent the letter, we can help. 

Thorn Law Group is comprised of former IRS attorneys who focus completely on successfully resolving complex tax matters and controversies. We are committed to discretion and aggressive representation with all our client cases, protecting your rights throughout every step of the way. Our tax lawyers have saved millions of dollars for clients and have helped them avoid severe IRS penalties. Let us do the same for you. 


There are two ways for taxpayers to comply with the FATCA: the Offshore Voluntary Disclosure Program (OVDP) and the Streamlined Offshore Disclosure Program. Below is a look at what each program entails.  

Offshore Voluntary Disclosure Program (OVDP)

OVDP is generally reserved for taxpayers who were “willful” (intentional) in their failure to comply with U.S. tax laws. During the OVDP process, taxpayers – including individuals, corporations, partnerships and trusts – must cooperate fully with the IRS at each step. As a result, this program is best suited for taxpayers who: 

  • Completely and voluntarily inform the IRS of tax violations
  • Have income from only legal sources
  • Make the disclosure prior to being informed that they are under criminal investigation
  • File a correct tax return or cooperate with the IRS in ascertaining their correct tax liability
  • Make full payment of the amount due, or if unable to do so, make arrangements to pay 

Streamlined Offshore Disclosure Program

Streamlined domestic and foreign offshore disclosure is better suited for taxpayers who are “non-willful,” meaning that their failure to report income, pay taxes and other failures to abide by tax laws were do to “negligence, inadvertence, or mistake of conduct that is the result of a good faith misunderstanding of the requirements of the law.”  

There are two Streamlined program options: The Streamlined Domestic Process is for U.S. taxpayers who reside in the U.S., while Streamlined Foreign Offshore Disclosure is for non-resident taxpayers who are also non-willful. 

If you are still confused about these programs, don’t worry, you are not alone. IRS tax laws are extremely complex, and just one wrong move can lead you to incur additional penalties and fees. We make sure this won’t happen to you. Our tax lawyers evaluate the individual details of your situation and determine which program will result in the best outcome for your case.  


Each tax lawyer at our firm understands what is at stake with any Foreign Bank Account Reporting matter. We work diligently to help you avoid tax penalties and get you to successfully comply with FATCA regulations. For swift, discrete and successful results with your Santander account matters, call Thorn Law Group at (202) 349-4033 or complete our online contact form.

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