The world is getting smaller by the day. Congress has enacted many laws requiring U.S. persons to report assets outside of the U.S. including foreign bank accounts, interests in foreign entities (corporations, partnerships, trusts), and much more. The law also requires reporting to the IRS by foreign owners of certain U.S. assets.

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The IRS uses the Foreign Account Tax Compliance Act (FATCA), income tax treaty exchange of information provisions, increased intergovernmental cooperation, whistleblower tips, information from other sources, and data analytics to actively hunt for taxpayers that fail to properly report foreign assets. Dan’s deep expertise concerning the IRS’ voluntary disclosure practice, the Streamlined Filing Compliance Procedures, and international penalty regimes allows him craft strategies to mitigate civil penalties and criminal exposure. Choosing the appropriate compliance path also involves understanding how the IRS may view your facts. Unfortunately, the IRS often misinterprets benign errors as tax fraud or willful reporting violations. Dan has the unique expertise to help you with the analysis.

 

Dan’s international tax and FBAR experience can help analyze whether you have potential reporting obligations or penalty exposure for the following international reporting forms:
 

• Form 926, Return by a U.S. Transferor of Property to a Foreign Corporation

• Form 3520-A, Annual Information Return of Foreign Trust with a U.S. Owner

• 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 5472, Information Return of a 25%  Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in U.S. Trade or Business

• Form 8621, Information Return by a Shareholder of a Passive Foreign Investment Company or Qualified Electing Fund

• Form 8854, Initial Expatriation Statement

• Form 8858, Information Return of U.S. Persons with Respect to Foreign Disregarded Entities (FDEs) and Foreign Branches (FBs)

• Form 8865, Return of U.S. Persons with Respect to Certain Foreign Partnerships

• Form 8938, Statement of Specified Foreign Financial Assets

• FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR)

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