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International Tax

The United States of America is one of the only countries across the world that utilizes an extra-territorial tax jurisdiction.  What this means is that the U.S. requires its citizens and resident aliens to report all income, regardless of where it was earned.  This broad mandate has caused significant controversy and non-compliance due to its complexity. Many U.S. citizens, resident aliens, and even tax professionals are completely unaware of the U.S. reporting requirements for international or offshore income and assets.  Failing to comply with these strict requirements can cause serious issues, including major civil penalties and even criminal prosecution. Our team of experts is ready to assist you if you are unsure about your U.S. reporting requirements for international or offshore income/assets.  You will speak directly with a tax attorney who will listen to your situation and then advise you of your options, including voluntary disclosure with the IRS.

IRS Voluntary Disclosures

Many U.S. citizens, including dual citizens, are often surprised to discover that their income earned overseas is generally taxable in the United States.  The U.S. also requires taxpayers to disclose the existence of their foreign assets, including bank accounts and real estate. Failure to disclose these assets and report any taxable income generated overseas can result in serious monetary penalties and even criminal prosecution.

Luckily, the government developed a voluntary disclosure programs to help provide relief to taxpayers who have not properly reported their offshore assets/income.  The two primary programs are the Offshore Voluntary Disclosure Program (“OVDP”) and the Streamlined Disclosure Program. Figuring out which program is right for you, in addition to several other alternatives, is typically complex.  Our team will learn the facts of your case and tailor a legal solution that ensures compliance and peace of mind.

NOTE: On March 13, 2018, the IRS announced that the OVDP would be closed on September 28, 2018. Taxpayers have limited time to submit a disclosure under the OVDP.

Tax Solutions for Non-U.S. Citizens

Many immigrants who come to the United States are surprised by the complexity of our tax code and their filing and compliance requirements.  This surprise often turns into fear and uncertainty when the IRS or a state taxing authority conducts an audit or other tax assessment. Our team understands the unique tax challenges facing foreign individuals and businesses and will work directly with you to resolve your issues.  We have a team of translators available.

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