International Tax Attorney
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International Tax Attorney

/International Tax Attorney
International Tax Attorney2018-05-17T17:39:28+00:00

international tax attorneyAn international tax attorney’s primary goal is to help our clients, including U.S. and foreign businesses, US. citizens, and foreign nationals, manage their tax burdens. At Randall & Associates, we help our clients understand their legal options and maximize their earnings and assets — while regaining compliance with U.S. tax laws.

We Can Help You Avoid Costly Mistakes

For many individuals and businesses, offshore bank accounts and assets are a normal part of their life and operations. This is particularly true if you’ve spent time as an expat or engage in global business. However, the U.S. Federal Government imposes a variety of filing and disclosure requirements on its citizens, U.S. corporations, legal residents, and foreign nationals and entities. This includes reporting foreign income and assets within foreign accounts under certain circumstances.

Failure to comply with the IRS’ laws and regulations can result in significant financial penalties and fines. And in the most serious cases, criminal charges. The penalties can be between 20 and 50% of your unpaid tax obligation. Failure to report an offshore bank account can result in up to $10,000 per year (per account) in fines.

What Do You Need to Report to the IRS?

Generally speaking, you must report:

  • Your offshore or foreign bank accounts
  • Most forms of  foreign assets
  • Foreign income and earnings, including both passive and interest income

What Type of Tax Forms Are Required?

international tax attorneyTo properly disclose these holdings, you’ll need to complete an array of tax forms. While the forms will vary, depending on your circumstances, they might include the Foreign Bank and Accounting Report (FBAR) and FATCA Form 8938. Other forms are required if you are the owner or beneficiary of a foreign trust, own foreign mutual funds, or have certain types of ownership in a foreign corporation. When in doubt, consult with an international tax attorney about your disclosure requirements, since tax laws and regulations frequently change.

Because the IRS is becoming increasingly aggressive with enforcement actions, it’s typically in your best interest to work with an international tax attorney and regain compliance. If you’re not actively the subject of an IRS investigation, you can avail yourself of a series of voluntary disclosure programs that allow you to report your offshore earnings and income, as well as catch up on your tax obligations.

Personalized and Practical Tax Solutions

Most of our clients didn’t willfully violate American tax laws. Instead, they were either unaware of the broad net that U.S tax laws throw, or didn’t realize the wide variety of reporting requirements involved. For example, many countries don’t tax certain forms of income (such as interest income), but the United States does. We can help you understand your obligations, minimize your penalties, and comply with U.S. federal laws.

International tax law involves a unique combination of both federal and international tax law and policy. At Randall & Associates, a skilled team of international law attorney will carefully assess your circumstances, calculate your potential penalties, unpaid taxes, and interest, and help you craft personalized international tax solutions that help you protect your assets.

Building a Tax Plan Tailored to Your Individual Needs

We know that your situation is unique. Rather than offer one-size-all solutions and scare tactics, we work closely and honestly with our clients. We’ll discuss your long-term goals, identify opportunities, and build a comprehensive international tax plan that helps you gain and maintain compliance. We’ll also help you fully understand your array of legal options, as well as guide you through the complicated nuances of international tax law.

You should also act quickly. The Offshore Voluntary Disclosure Program (OVDP) is ending in September 2018. If you have questions about the termination of this program and your legal options, contact an international tax attorney at Randall & Associates immediately.

Assessing Your Offshore Voluntary Disclosure Options

Our practice focuses primarily on Offshore Voluntary Disclosures. These complex processes require a detailed analysis of your individual facts, immigration status, marital status, and other factors. Depending on your needs, we might consider the following options:

  • Offshore Voluntary Disclosure Program (OVDP). This allows those with willful violations to regain compliance through a series of amended tax filings, interest, and penalties. If you are currently the subject of an IRS examination or investigation, you are not eligible for OVDP.
  • Streamlined Offshore Disclosures. A cost-effective method of disclosure available to certain, eligible taxpayers who are foreign residents and had reasonable cause or made non-willful violations. You might also qualify for a penalty waiver, but you’ll still have to pay your unpaid taxes and interest.
  • Reasonable Cause. Technically, “reasonable cause” isn’t a disclosure program. Instead, it’s a way to potentially avoid tax penalties for your non-disclosure and failure to report. This process requires a careful, factual analysis from a skilled international law attorney.

Based on your unique needs, we’ll build a solution that advances both your personal or organizational interests.

Can I Ignore the IRS’ Reporting and Filing Requirements?

It might be tempting to ignore the IRS’ complicated reporting and filing rules. However, it’s never in your best interest to wilfully evade U.S. tax laws. Instead, consult with an international tax lawyer who can help you construct a reasonable solution.

If the IRS discovers your noncompliance, you might face significant penalties. This includes tax liens, levies, fines, penalties, and the revocation of your passport. Under very serious circumstances, you might face criminal charges from the Department of Justice and IRS. Or you may face deportation if you’re a foreign national. The longer you wait, the larger your penalties. And the harder it will be to convincingly argue that your violations were non-willful or that you had reasonable cause.

Schedule a Confidential Evaluation With an International Tax Attorney

Without guidance from an experienced international tax attorney, even the savviest business people can make costly mistakes. At Randall & Associates, we focus on international tax issues, including compliance and litigation. If you have questions about your IRS filings, received a FATCA letter, or were recently contacted by the IRS, schedule a confidential, no-risk evaluation with our team. We can help you understand the extent of your potential liabilities. We will also advise you of your legal options, and construct a customized plan that meets both your long and short-term goals.