top of page

International Tax Law

International Tax Problems Lawyer

In the past, Swiss bank accounts were nearly impenetrable. And for many other countries, the IRS had no way of finding out that a U.S. taxpayer has any foreign financial accounts or foreign assets. That is no longer the case. Foreign Bank Account Reporting (FBAR) regulations for offshore accounts have made it much easier for the IRS to obtain information about foreign assets and offshore financial accounts. The IRS is taking advantage of this fact, hiring more and more staff to focus specifically on overseas accounts to ensure that money is not being deposited overseas unreported. Individuals caught doing so could face serious consequences.

If you have a financial interest in or signature authority over a foreign financial account, the Bank Secrecy Act may require you to report the account yearly to the Internal Revenue Service by filing Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR). In addition, the recent rule requires the taxpayer to file a new IRS Form 8938 with their income tax return (Form 1040) to report specified foreign financial assets (SFFAs). This reporting is required under the Foreign Account Tax Compliance Act (FATCA), which was enacted in 2010.

The IRS prefers that you come forward and voluntarily disclose your foreign assets or foreign bank and financial accounts. For this reason, the IRS came up with an Offshore Voluntary Disclosure Program (OVDI). The first OVDI program ran in 2009, the second one in 2011, and the most recent one was announced in 2012. We assisted many taxpayers get more favorable tax treatment of their foreign income via participation in these OVDI programs.

The Bellevue, Washington, law firm of Lana Kurilova Rich PLLC is dedicated to preventing these consequences for people in the Greater Seattle area, statewide and nationwide. If you have Swiss bank accounts or other overseas accounts that you believe could lead to international tax problems with the IRS, or if you have already been contacted by the IRS, call us at 866-418-3175 for an initial phone consultation.

More Than Just a Bill for Back Taxes — Seek Business Taxation Assistance From Our Washington Attorney

 

Offshore bank accounts and other foreign assets could lead to much more than a bill for unpaid taxes. If the IRS discovers a foreign account and believes that money has been intentionally hidden there, the matter could escalate to the level of criminal tax evasion charges.

It is important to note that, even if the money was not smuggled into the offshore account tax-free, it is likely that interest accumulated in that account has not been taxed properly. Many of the taxpayers subject to IRS actions in these situations are individuals who had accounts established while living and working overseas; these people may have forgotten about their foreign accounts entirely. The IRS may not see this as an excuse, especially when foreign accounts show substantial balances.

If you are aware of an offshore account that has not been reported to the IRS, we can work with you to determine your best option for resolving the matter, which may include amending tax returns to include that account and going through the IRS Offshore Voluntary Disclosure Initiative (OVDI), if it is still available. A settlement may be a possibility. If the IRS has already discovered your foreign account and OVDI is no longer an option for you, we will use our experience to mitigate repercussions.

Seattle, Washington, Lawyer, Helping With Unpaid Back Taxes and Other International Tax Issues

 

We also address these issues:

Call (425) 289-0629 for an Initial Phone Consultation

 

We invite you to contact us today by phone or by e-mail to discuss your case with our experienced Washington business taxation lawyer. Find out how we can help.

U.S. Taxes When Living And Working Abroad ›

bottom of page