International Tax Consulting

International Tax Compliance

Unwanted Attention From the IRS? Let Us Take the Reins

International Tax Attorneys | Reporting of Foreign Assets

Has IRS scrutiny resulted in questions about your foreign accounts? Taxpayers with foreign assets can be caught off-guard by IRS reporting requirements. Protect your investments and gain clarity about international disclosure requirements without letting them cause you undue frustration. Let our team of dual-licensed tax attorneys and CPAs at Frost Law help you today.

Frost Law can help you with common international tax problems such as:

  • Filing requirements
  • Penalties and violations
  • Reporting thresholds
  • Voluntary disclosures
  • Investigations and other international tax issues

Form 3520 Filing Obligations & IRS Notice CP15

Form 3520 follows the IRS tax return deadline and is due April 15th. Form 3520-A, which is closely related to Form 3520, deals with trusts that have more than one owner, amongst other differences and it has a separate filing deadline. If you forgot to file either Form 3520 or Form 3520-A then you may end up dealing with a letter from the IRS labeled as Notice CP15, which details penalty issues.

If you’re uncertain about how to respond to Notice CP15 or have other questions about Form 3520 filing, we can help you identify your options and make a decision on the best course of action for penalty abatement.

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Call us at 410-497-5947 or fill out our contact form for a consultation.

FBAR Obligations, Violations & Penalties

FBAR stands for “Foreign Bank Account Report,” and refers to FinCen Form 114, Report of Foreign Bank and Financial Accounts.

FBAR added new obligations for some U.S. taxpayers who have ownership or control (for example signature authority) of foreign accounts with an aggregate value of over $10,000 in the calendar year: typically, taxpayers in that situation might have an FBAR filing required.

If you’re uncertain about how the disclosure requirements apply, we can help you identify your options and make a decision on the best course of action going forward.

After a foreign bank reports the non-compliant taxpayer’s account information to the foreign taxing authority, the information is then provided to the U.S. Dept Treasury. For those countries without intergovernmental agreements (IGAs), the account holder’s information will be sent directly to the U.S. Dept of Treasury. Or the IRS may have discovered the non-compliance based on stated or implied sources of foreign income on filed tax returns or information forms. Regardless of how the IRS obtains the information, what could follow is an investigation by an IRS examiner of the potential FBAR violation(s).

FBAR violations lead to civil and/or criminal penalties. The monetary penalty may not exceed $10,000 per violation; however, where the violation is willful, the penalty is the greater of $100,000 or 50% of the balance in the account on the date of the violation.

The Delinquent FBAR Submission Procedures are one of the programs available under the Offshore Voluntary Disclosure Program (OVDP) for taxpayers with unreported foreign financial accounts to come into compliance.

FATCA Reporting

FATCA added new obligations for U.S. taxpayers holding offshore accounts to report those holdings to the IRS through intergovernmental agreements (IGAs) with more than 100 countries. FATCA typically requires U.S. taxpayers who meet the FATCA threshold (at least $50,000) to report information on their assets on form 8938.

Unsure if you have IRS reporting requirements? Frost Law can help you identify your options and make a decision on the best course of action going forward.

FATCA Withholding

The world of FATCA withholding breaks down into two major categories, foreign financial institutions (FFIs) and non-financial foreign entities (NFFEs). There are a set of hard and fast rules that are applicable to these groupings – although, in the case of an individual business, it is always best to consult with an international tax attorney to ensure correct filing.

Different types of NFFEs and FFIs have varied obligations with respect to the FATCA withholding tax so it’s important to contact an attorney for accurate guidance.


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