International tax attorneys for foreign accounts, expats, and cross-border businesses
A bank account abroad, an inheritance from overseas, years living outside the United States without filing, or a foreign company you did not know you had to report. The penalties in this area are among the largest in the tax code, and most of them are avoidable if you act before the IRS does.
International tax services
The right program depends on where you live and whether the failure was willful. Start with the situation that matches yours.
Willful or not is the whole case.
Every offshore matter turns on one question: was the failure to report willful? Non-willful taxpayers can use the streamlined procedures and pay a 5 percent penalty or none. Willful taxpayers need the Voluntary Disclosure Practice and face a fraud penalty. Certifying non-willfulness when the facts say otherwise turns a fixable problem into evidence.
That judgment is legal, not accounting, and it is made under attorney-client privilege before anything is filed. Once made, our accounting team prepares the returns and FBARs under the attorney’s engagement. The firm has guided clients through more than 100 streamlined disclosures.
Results depend on the facts of each matter and are not a prediction of the outcome in your case.
The streamlined procedures explained in four minutes.
Who handles international tax matters
Offshore matters are handled by attorneys who decide the willfulness question under privilege, with the accounting team preparing the filings.
Questions people ask before they call
Straight answers to the questions that come up first. The consultation is where we answer the rest.
Probably less than you fear, if you act now. Most first-time failures are non-willful and can be fixed through the streamlined procedures with a reduced or zero penalty. The mistake to avoid is filing quietly or certifying non-willfulness without having the facts reviewed.
The FBAR threshold is 10,000 dollars in aggregate across all foreign accounts at any point in the year, so several small accounts can add up to a filing. Form 8938 has higher thresholds. A crypto-only account on a foreign exchange is not currently reportable on the FBAR, but an account that also holds fiat is.
Often little or none once the foreign earned income exclusion or foreign tax credit is applied, but only if you file. The Streamlined Foreign Offshore Procedures accept original returns for the past three years with no offshore penalty for non-willful taxpayers.
Frequently, yes. International information return penalties are assessed automatically, and reasonable cause requests, the delinquent international information return procedures, and appeals remove many of them. The request has to be documented and made in time.
Both, in the right order. The willfulness analysis and the program choice are legal decisions made under privilege by the attorney. The returns and FBARs are prepared by our accounting team under the attorney’s engagement, so the two never work at cross purposes.
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Tell us what is going on. A member of our client success team follows up, explains how we work, and matches you with the attorney whose background fits your matter.
