The federal government’s taxation powers extend beyond the country’s borders. Glen E. Frost can protect your rights in international tax litigation matters, and can help safeguard your interests if you are a U.S. resident, U.S. citizen residing abroad, or have foreign bank accounts.

Foreign Bank Account Reporting Compliance
The IRS pays close attention to Foreign Bank Account Reporting compliance. It is important to know that if you have $10,000+ in foreign bank account(s) or investment(s), you must file an FBAR (Report of Foreign Bank and Financial Accounts). In late 2013, the Form 114 FBAR replaced the form TD F 90-22.1 which was used in prior years.

Offshore Voluntary Disclosure Program
Taxpayers who have unreported foreign income and/or unreported foreign bank accounts may be eligible for the IRS Offshore Voluntary Disclosure Program (OVDP). In order to comply with OVDP amnesty terms, you must:

  • File all original and amended tax returns that report worldwide income for the past 8 tax years
  • File all FBARs for the past 8 tax years
  • Pay back taxes, interests and any penalties for the past 8 tax years

The Foreign Account Tax Compliance Act
Beginning on July 1, 2014, foreign financial institutions are required to follow the terms of the Foreign Account Tax Compliance Act (FATCA). FATCA requires these institutions to provide information on U.S. account holders to the U.S. government. This information will including taxpayer names, addresses, and largest account balance of the year. International tax enforcement is increasing dramatically and, if you have foreign accounts, it is imperative to contact a tax lawyer to find out how FATCA may affect you.

Offshore Tax Issues
We have extensive experience handling a wide range of offshore tax issues, including:

  • Form 3520 Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts
  • Form 5471 Information Return of U.S. Persons With Respect To Certain Foreign Corporations
  • Form 8621 PFIC/Passive Foreign Investment Company Reporting
  • Form 8891 U.S. Information Return for Beneficiaries of Certain Canadian Registered Retirement Plans
  • Form 8938 Statement of Specified Foreign Financial Assets