Offshore Tax Compliance
The firm has substantial experience in representing individuals with offshore compliance issues with the Internal Revenue Service. We have represented clients in Brazil, Mexico, Canada, China, Taiwan, Philippines, Lebanon, the Netherlands, Israel, Germany, England, Indonesia, Malaysia, Australia, Italy, and France. Our lawyers have successfully resolved cases in the following programs:
- Streamlined Filing Compliance Procedures
- Delinquent FBAR Submission Procedures
- Delinquent International Information Return Submission Procedures
- 2012 Offshore Voluntary Disclosure Program (now closed)
- IRS Voluntary Disclosure Practice
The firm also represents clients who are the subject of a civil examination and have offshore compliance issues such as undisclosed foreign financial accounts or assets. Our lawyers aggressively seek to minimize the client’s exposure to civil penalties for failing to file information returns and are knowledgeable with respect to the complex procedural rules surrounding information return penalties such as delinquent FBARs, Form 8938 and Form 5471.
Individual International Tax
The firm has handled numerous cases involving clients with individual international tax issues. Often, our clients are either moving to the United States for work or are departing the country to return home when tax issues arise. A sampling of the firm’s work includes:
- Clients who seek to expatriate or relinquish their U.S. citizenship or long-term resident status.
- Green card holders who have tax compliance issues with the Internal Revenue Service.
- Foreign investment of real estate in the United States.
- Individuals who move to the United States from another country (pre-immigration planning).