Offshore Tax Attorney for International Tax Accounting Done Right

International Tax Services for U.S. Taxpayers with Global Finances

Whether you live abroad, earn foreign income, own offshore accounts, or operate an international business, U.S. tax law follows you everywhere. Our international tax attorneys help you meet IRS reporting requirements, avoid penalties, and structure your tax efficiency.

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Work With The Best International Tax Attorneys

International tax rules are among the most complex in the U.S. tax code, and the penalties for non-compliance are severe. FBAR penalties alone can reach 50% of your account balance per year for willful violations. Form 5471 penalties start at $10,000 per form, per year and multiply quickly.

Many taxpayers face penalties exceeding the value of their foreign accounts simply because they didn’t know the reporting requirements existed. If you have foreign income, offshore accounts, or international business interests, you need real international tax lawyers who specialize in cross-border taxation.

Our Role as Your International Tax Lawyer

Identify your reporting obligations: We analyze your foreign assets, income, and business interests to determine exactly which forms you must file and which deadlines apply.
Prepare complex international returns: We handle FBAR, FATCA, Form 5471, Form 8865, Form 3520, PFIC reporting, and other international filings that most tax preparers aren't qualified to complete.
Minimize your global tax burden: We use foreign tax credits, treaty benefits, exclusions, and entity structuring to reduce your U.S. tax liability while keeping you fully compliant.

Resolve past non-compliance: We guide you through Streamlined Procedures, delinquent filings, or voluntary disclosure to correct prior years with reduced or eliminated penalties.
Defend against IRS penalties: We respond to penalty notices, argue reasonable cause, and negotiate abatement when the IRS assesses international information return penalties.
Protect your communications: Unlike CPAs, our attorney-client privilege ensures your disclosures about past non-compliance remain confidential and cannot be used against you.

What is International Tax Compliance?

International tax compliance is meeting U.S. reporting requirements for foreign income, foreign assets, and cross-border financial activity. The United States taxes its citizens and residents on worldwide income, regardless of where they live or where the money is earned. Beyond paying taxes on foreign income, U.S. taxpayers must file information returns disclosing foreign bank accounts (FBAR), foreign financial assets (FATCA), interests in foreign corporations (Form 5471), foreign partnerships (Form 8865), foreign trusts (Form 3520), and other offshore holdings.

Who We Help With International Tax Services

The United States taxes its citizens and residents on worldwide income, regardless of where they live or where the money is earned. If you have any financial connection outside the U.S., you likely have reporting obligations that go far beyond a standard 1040. Failing to meet these requirements can result in penalties that exceed the value of the accounts themselves.

U.S. Expats Living Abroad

If you’re an American citizen or green card holder living outside the United States, you must still file U.S. tax returns every year. You’re taxed on your global income, though foreign tax credits and the Foreign Earned Income Exclusion may reduce your U.S. liability. You must also report foreign bank accounts, foreign financial assets, and any foreign business interests. Many expats don’t realize these obligations exist until they face penalties or try to return to the U.S.

U.S. Residents with Foreign Assets

Even if you’ve never left the country, holding foreign bank accounts, investments, retirement accounts, or real estate creates reporting requirements. Accounts exceeding $10,000 in aggregate at any point during the year trigger FBAR filing. Higher thresholds trigger Form 8938 under FATCA. Failure to file these forms, even if you owe no additional tax results in substantial penalties.

Foreign Nationals in the U.S.

Non-U.S. citizens who become U.S. residents for tax purposes (green card holders or those meeting the substantial presence test) face the same worldwide taxation as U.S. citizens. The transition from non-resident to resident status creates complex tax situations, especially regarding foreign assets acquired before U.S. residency.

Business Owners with International Operations

If you own or have an interest in a foreign corporation, partnership, or trust, you face a web of information reporting requirements: Form 5471 for controlled foreign corporations, Form 8865 for foreign partnerships, Form 3520 for foreign trusts, and potentially GILTI, Subpart F, and PFIC reporting. The penalties for missing these forms start at $10,000 each and can multiply quickly.

Dual Citizens

Holding citizenship in the U.S. and another country creates overlapping tax obligations. You may owe taxes to both countries on the same income. Proper planning using tax treaties and foreign tax credits prevents double taxation, but requires careful analysis of both countries’ tax systems.

Inheritors of Foreign Assets

Receiving an inheritance from a foreign person or estate triggers reporting requirements even if no U.S. tax is owed. Gifts or bequests from foreign persons exceeding $100,000 must be reported on Form 3520. Foreign trusts and inherited foreign accounts create ongoing compliance obligations.

International Tax Planning & Legal Offshore Tax Strategies

Proper international tax planning can significantly reduce your U.S. tax liability while keeping you fully compliant. Our international tax advisors help you structure your global finances for maximum tax efficiency.

FBAR Compliance and Filing

U.S. taxpayers with foreign financial accounts exceeding \$10,000 in aggregate at any point during the year must file an FBAR (FinCEN Form 114) annually. This includes bank accounts, brokerage accounts, mutual funds, and many foreign pension accounts. We prepare and file FBARs for individuals and businesses, identify all accounts that trigger reporting requirements, and ensure timely submission. For taxpayers with signature authority over employer or business accounts abroad, we clarify your individual filing obligations.

Foreign Account Planning Strategies

Strategic planning around foreign accounts can reduce your reporting burden and minimize penalty exposure. We help you structure account ownership to simplify reporting, identify accounts that qualify for FBAR exceptions, and time account closures or transfers to reduce compliance complexity. For clients considering opening new foreign accounts or restructuring existing ones, we advise on the tax and reporting implications before you act.

Offshore Asset Reporting (FATCA)

U.S. taxpayers with specified foreign financial assets exceeding \$50,000 (higher thresholds for expats) must report them on Form 8938 under FATCA. This includes foreign bank accounts, foreign stocks and securities, interests in foreign entities, and foreign-issued life insurance policies. Form 8938 is filed with your tax return and has different requirements than FBAR—many taxpayers must file both. We identify which assets require reporting, prepare Form 8938 accurately, and ensure you meet both FBAR and FATCA obligations.

Offshore Asset Structuring

How you hold offshore assets affects both your reporting requirements and tax liability. We analyze your foreign investments, business interests, and financial accounts to identify optimal ownership structures. This includes evaluating whether foreign entities should be treated as corporations, partnerships, or disregarded entities for U.S. tax purposes and restructuring when the current setup creates unnecessary complexity or tax exposure.

Tax Treaty Benefits

The U.S. has income tax treaties with over 60 countries. These treaties can reduce withholding rates on dividends, interest, and royalties; determine which country has primary taxing rights over specific income; and prevent double taxation. We analyze applicable treaties to ensure you receive all available benefits.

Foreign Earned Income Exclusion

U.S. citizens and residents living abroad may exclude up to $126,500 (2024) of foreign earned income from U.S. taxation if they meet either the bona fide residence test or physical presence test. Combined with the foreign housing exclusion, this can eliminate U.S. tax liability for many expats. We ensure you qualify and claim the maximum exclusion.

PFIC Planning

Passive Foreign Investment Company rules impose punitive taxation on U.S. shareholders of foreign mutual funds and similar entities. Proper planning—including QEF and mark-to-market elections—can mitigate these harsh rules. We identify PFICs in your portfolio and implement strategies to minimize the tax impact.

Foreign Tax Credits

If you pay taxes to a foreign country on income that's also taxable in the U.S., you may claim a foreign tax credit to avoid double taxation. This is often more valuable than the Foreign Earned Income Exclusion for expats in high-tax countries. We analyze your complete tax picture to determine which approach saves you more.

Don't Let Foreign Accounts Become a Crisis.

International tax penalties can exceed the value of your offshore accounts. Our international tax attorneys have helped clients come into compliance, eliminate penalties through voluntary disclosure, and resolve years of unfiled FBARs. Contact us before the IRS contacts you.

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Our International Tax Services

We provide comprehensive international tax services covering every aspect of cross-border tax compliance and planning. Our team includes tax attorneys, CPAs, and enrolled agents with deep experience in international tax matters.

International Tax Compliance Services

✓FBAR preparation and filing (FinCEN Form 114)
✓FATCA reporting (Form 8938)
✓Foreign corporation reporting (Form 5471)
✓Foreign partnership reporting (Form 8865)
✓Foreign trust reporting (Form 3520 and 3520-A)
✓PFIC reporting (Form 8621)
✓Foreign tax credit calculations (Form 1116)
✓Foreign Earned Income Exclusion (Form 2555)
✓Tax treaty-based position reporting (Form 8833)

Offshore Tax Preparation Services

✓Expat tax return preparation
✓Tax returns with foreign income from wages, investments, rental property, and business
✓Multi-country tax filings with treaty analysis
✓Back-year tax returns for non-filers
✓Amended returns correcting international reporting errors

International Tax Planning Services

✓Pre-immigration tax planning for incoming residents
✓Expatriation planning and exit tax analysis
✓Foreign tax credit vs. exclusion optimization
✓Entity structure planning for foreign operations
✓PFIC mitigation strategies
✓Tax treaty benefit analysis
✓Foreign retirement account planning
✓Cross-border estate and gift planning

International Tax Advisory Services

✓IRS notice response for international penalties
✓Penalty abatement requests for reasonable cause
✓Streamlined filing compliance procedures
✓Delinquent FBAR and information return submissions
✓Voluntary disclosure representation
✓IRS examination defense for international issues
✓Appeals representation

International Tax Consulting Services

✓Foreign investment due diligence
✓Cross-border transaction structuring
✓Foreign business expansion tax analysis
✓Compliance system implementation
✓Ongoing international tax monitoring

Offshore Account Disclosure: Options for Past Non-Compliance

If you’ve failed to report foreign accounts or income in prior years, you’re not alone. Many taxpayers don’t learn about FBAR and international reporting requirements until years after they should have been filing. The good news: voluntary disclosure options exist that can eliminate or significantly reduce penalties.

IRS Streamlined Filing Compliance Procedures

The Streamlined Procedures are available to taxpayers whose failure to report foreign financial assets and pay all tax due was non-willful. This is the most common path for expats and accidental Americans who simply didn’t know about their obligations.

Requirements include filing amended returns for the past 3 years and FBARs for the past 6 years, along with a certification statement explaining the non-willful conduct.

Delinquent FBAR Submission Procedures

If you failed to file FBARs but have no unreported income and owe no additional tax, you may be able to file late FBARs without penalty through the Delinquent FBAR Submission Procedures. You must include a statement explaining why the FBARs are late.

Delinquent International Information Return Submission Procedures

Similar procedures exist for late Forms 5471, 8865, 3520, and other international information returns when reasonable cause exists for the late filing.

Voluntary Disclosure Practice

For taxpayers who cannot certify non-willful conduct, meaning they knew about their obligations and chose not to comply, the IRS Voluntary Disclosure Practice remains an option. This involves full disclosure to IRS Criminal Investigation and typically results in significant penalties, but avoids criminal prosecution.

Why Choose Silver Tax Group for International Tax Services

International tax is one of the most complex areas of U.S. tax law. The rules change frequently, penalties are severe, and mistakes can be costly.

Deep International Tax Experience

Our team focuses on international tax matters daily. We handle FBAR and FATCA filings, voluntary disclosures, foreign corporation and partnership reporting, expatriate returns, and cross-border planning for clients across the globe. This isn’t a sideline for us—it’s core to our practice.

Attorney-Client Privilege

Unlike accountants and tax preparers, communications with our attorneys are protected by attorney-client privilege. This really matters when discussing past non-compliance. Your accountant can be compelled to testify against you; your attorney cannot. For sensitive international matters, working with a tax attorney provides protection that CPAs can’t offer.

Both Compliance and Planning

Many firms focus only on compliance by filing the required forms. We go further by actively planning to reduce your tax burden. Compliance keeps you out of trouble; planning keeps more money in your pocket. You need both.

Penalty Reduction Experience

When penalties are assessed, we fight to reduce or eliminate them. We’ve successfully obtained penalty abatement through reasonable cause arguments, first-time abatement, and statutory defenses. Our experience with IRS international penalty procedures helps us achieve outcomes that generalist firms cannot.

Global Perspective

We work with clients living in countries around the world, from Europe and Asia to Latin America and the Middle East. We understand the practical challenges expats face and the specific tax rules that apply to different countries through U.S. tax treaties and local tax systems.

Flat-Fee Pricing

International tax matters can be complex, but that doesn’t mean you should face unpredictable hourly bills. We provide flat-fee quotes for most services so you know exactly what you’ll pay before we begin.

Frequently Asked Questions About International Tax Services

Do I need to report foreign bank accounts to the IRS?

Yes, if your foreign financial accounts exceed $10,000 in aggregate at any point during the year, you must file an FBAR (FinCEN Form 114). This includes bank accounts, brokerage accounts, mutual funds, and many foreign pension and retirement accounts. The FBAR is filed separately from your tax return through FinCEN’s electronic filing system. Failure to file can result in penalties up to $10,000 per account for non-willful violations, or the greater of $100,000 or 50% of account balances for willful violations.

What is the difference between FBAR and FATCA?

FBAR (FinCEN Form 114) and FATCA (Form 8938) are separate reporting requirements with different thresholds and different filing procedures. FBAR requires reporting foreign accounts exceeding $10,000 in aggregate and is filed electronically with FinCEN. FATCA requires reporting specified foreign financial assets exceeding $50,000 (higher for expats) and is filed with your tax return. Many taxpayers must file both. The forms cover overlapping but not identical categories of assets, and each has its own penalty structure.

What happens if I haven't reported my foreign accounts?

You have options to come into compliance. The IRS Streamlined Filing Compliance Procedures allow eligible taxpayers to file back returns and FBARs with reduced or no penalties if their failure to comply was non-willful. Streamlined Foreign Offshore (for expats) has no penalty; Streamlined Domestic Offshore (for U.S. residents) has a 5% penalty. The Delinquent FBAR Submission Procedures may allow penalty-free filing if you have no unreported income. We evaluate your situation and recommend the best path forward.

What is the Streamlined Filing Compliance Procedure?

The Streamlined Procedures are IRS programs that allow taxpayers to catch up on international reporting without facing the full penalties that would otherwise apply. They require filing 3 years of amended tax returns and 6 years of FBARs, along with a certification that your failure to comply was non-willful. Streamlined Foreign Offshore (for taxpayers outside the U.S.) has no penalty. Streamlined Domestic Offshore (for U.S. residents) has a 5% penalty on foreign asset values. These programs are only available to taxpayers who haven’t been contacted by the IRS.

Get Your International Tax Questions Answered

Our international tax attorneys and advisors have helped hundreds of clients meet their global reporting obligations, come into compliance through voluntary disclosure, and reduce their worldwide tax burden through proper planning.