Options Available For U.S. Taxpayers with Undisclosed Foreign Financial Assets

For taxpayers who have undisclosed foreign financial assets and/or income, the IRS provides several options to remedy previous failures to comply with US tax and information reporting obligations. These options include:

•  Offshore Voluntary Disclosure Program (OVDP)
•  Streamlined Domestic Offshore Procedures
•  Streamlined Foreign Offshore Procedures
•  Delinquent FBAR submissions procedures
•  Delinquent international information return submission procedures

Read more about offshore compliance options.

Why Choose Us for your Offshore Tax Compliance Matter?

Reason #1 Experience

Before starting my law practice, I worked at a large accounting firm practicing in expatriate and foreign national tax, which is a specialized area of tax. Most tax attorneys do not understand the accounting aspect of offshore tax compliance. And accountants that do understand expat tax can’t offer you attorney-client privilege, which is vital for individuals with unreported foreign assets. I am able to offer you both.

In addition, only a small percentage of tax attorneys that practice in this area have experience at the IRS. My experience working at the IRS has added significant value to my clients. I know compliance officers, revenue agents, revenue officers, criminal investigators and attorneys at the IRS or that have previously worked there. It helps to have an understanding of the internal operations at the IRS.

Reason #2 Personal Attention

Some clients will undoubtedly fall for firms that are more interested in marketing and chasing clients for 5 star reviews than in your case. Unless you’re a sophisticated client, you’ll never know if the optimal tax position was taken on your returns – Were applicable tax treaties reviewed? Were all foreign tax credits included? Could some of the income have been legally excluded? You could walk away impressed that your streamlined or OVDP application was completed quickly and “went through” but what you don’t know is that you may have overpaid your taxes, maybe even by a substantial amount.

Example: A client came to us after having paid substantial legal fees to a firm, and a hefty 5% misc. offshore penalty under the streamlined domestic offshore procedures. In their haste to complete to complete the client’s returns and move on to the next case, the firm did not consider that the client qualified to file under the streamlined foreign offshore procedures. Normally this client would not have qualified because he was in the US for more than 183 days for each of the three most recent tax periods; however, he was on an F-1 visa in year 1, which exempts him from the substantial presence test for that period. With a highest account balance of $300,000, this client paid a $15,000 misc. offshore penalty that would not have been assessed under the foreign offshore procedures. If I had not informed this client about his other option, he would have been blissfully unaware!

An attorney who is running multiple offices does not have time to be substantially involved in your case. I run a small practice out of Houston and give every case the attention it deserves. Offshore compliance is a personal and sensitive matter. Each case is unique, and as a client you should demand that your legal representative listen to you and understand your particular situation.

Reason #3 Results

I have successfully represented clients with offshore assets held across the globe such as in Australia, Switzerland, Singapore, S. Korea, China, India, UK, Argentina, and elsewhere.