International Tax Law

Baltimore International Tax Lawyers

Foreign Bank Account Reporting Compliance
The IRS pays close attention to Foreign Bank Account Reporting compliance. If you have $10,000+ in a foreign bank account or investment, 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. FBARs are due by June 30th and the penalty for not filing can be steep. Contact us to help you get into compliance before penalties are assessed.

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

  • File original and amended tax returns reporting international income for the past 8 tax years
  • File FBARs for the past 8 tax years
  • Pay back taxes, interests and 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 U.S. account-holder information to the U.S. government with the purpose of ensuring taxpayers have been reporting earnings in foreign bank accounts. This information will including taxpayer names, addresses, and largest account balance of the year. If you have a foreign bank account, you should contact a tax lawyer immediately 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