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International Tax & Offshore Tax Compliance Attorneys

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. 

  • FBAR Filings
  • Foreign tax credits
  • Cross border tax planning
  • FATCA Compliance
  • Flat-Fee Pricing

Schedule a Free Consultation Now

Your information is 100% confidential and protected.

Silver Tax Group has a 10/10 rating for being a top tax lawyer.
Silver Tax Group is a top-rated Tax Law firm on FindLaw in 2025.
Chad C. Silver is rated as a Rising Star on SuperLawyers.
Chad Silver is rated 5/5 as an Elite Tax Lawyer.
Silver Tax Group has a 10 star lawyer rating on Justia.
Chad Silver won the 5/5 Stars Lawyers of Distinction Award.
Silver Tax Group has a 5 star rating on BBB.
Silver Tax Group awarded the best US tax law firm in 2025.
Best Corpus Christi, Texas IRS tax attorneys for state and federal taxes.

Work With The Best International Tax Attorneys

International tax rules are some of the hardest to understand in the U.S. tax code. The penalties for not following them are serious. FBAR penalties can reach 50% of your account balance per year if you break the rules on purpose. Form 5471 penalties start at $10,000 per form, per year and grow from there.

Many taxpayers pay penalties that exceed the value of their foreign accounts because they didn’t know the reporting requirements existed. If you have foreign income, offshore accounts, or international business interests, you need international tax lawyers who focus on cross-border taxation.

Our Role as Your International Tax Lawyer

  • ✓Find out what you need to report: We review your foreign assets, income, and business interests to determine which forms you must file and when they are due.
  • ✓Complete international tax forms: We handle FBAR, FATCA, Form 5471, Form 8865, Form 3520, PFIC reporting, and other international filings that most tax preparers can’t complete.
  • ✓Lower your tax bill: We use foreign tax credits, treaty benefits, exclusions, and business structures to reduce your U.S. tax bill while keeping you compliant.
  • ✓Fix past filing problems: We guide you through Streamlined Procedures, late filings, or voluntary disclosure to correct prior years with reduced or eliminated penalties.
  • ✓Fight IRS penalties: We respond to penalty notices, explain your reasons for late filing, and negotiate penalty removal when the IRS charges you for missing international forms.
  • ✓Protect your information: Unlike CPAs, our attorney-client privilege keeps your disclosures about past filing problems confidential and prevents them from being used against you.

What is International Tax Compliance?

International tax compliance means following U.S. rules for reporting foreign income, foreign assets, and money that moves between countries.

The United States taxes its citizens and residents on all income earned worldwide. Meaning you have to pay taxes on foreign income and file forms that report foreign bank accounts (FBAR), foreign financial assets (FATCA), ownership in foreign corporations (Form 5471), foreign partnerships (Form 8865), foreign trusts (Form 3520), and other accounts outside the U.S.

Who We Help With International Tax Services

If you have any financial connection outside the U.S., you probably have to file more forms than just a standard 1040. If you don’t meet these requirements, you can face penalties that are larger than the value of your accounts.

U.S. Expats

American citizens and green card holders must file U.S. tax returns every year, no matter where they live. The U.S. taxes your worldwide income. Foreign tax credits and the Foreign Earned Income Exclusion can reduce what you owe. You also need to report foreign bank accounts, financial assets, and business interests. Most expats don’t learn these rules exist until they face penalties or try to return to the U.S.

U.S. Residents with Offshore Assets

If you own foreign bank accounts, investments, retirement accounts, or real estate, you have to report them. When your accounts total more than $10,000 at any point during the year, you must file an FBAR. If you have even more money abroad, you also need to file Form 8938 under FATCA. Missing these forms means big penalties, even when you don’t owe any tax.

Foreign Nationals in the U.S.

Non-U.S. citizens who become tax residents follow the same rules as U.S. citizens. This includes green card holders and anyone who meets the substantial presence test. The U.S. taxes your worldwide income once you qualify as a resident. The switch from non-resident to resident status creates complications, especially with assets you owned before becoming a U.S. resident.

Business Owners with International Operations

If you own part of a foreign corporation, partnership, or trust, you face many reporting requirements. You need Form 5471 for controlled foreign corporations, Form 8865 for foreign partnerships, and Form 3520 for foreign trusts. You may also need to report GILTI, Subpart F, and PFIC income. Missing these forms costs at least $10,000 each. The penalties add up fast when you miss multiple forms.

Dual Citizens

If you’re a citizen of both the U.S. and another country, you have tax responsibilities in both places. You might owe taxes to both countries on the same income. Tax treaties and foreign tax credits can stop you from paying twice. But you need to understand how both countries’ tax systems work to get this right.

Inheritors of Foreign Assets

Getting an inheritance from someone outside the U.S. means you have to report it, even when you don’t owe tax. If a foreign person gives you or leaves you more than $100,000, you must file Form 3520. Foreign trusts and foreign accounts you inherit require you to file reports every year after that.

International Tax Planning & Legal Offshore Tax Strategies

Good international tax planning can lower your U.S. tax bill while keeping you compliant. Our international tax advisors help you organize your money around the world so you pay the least tax legally allowed.

FBAR Compliance and Filing

If you have foreign financial accounts worth more than $10,000 at any time during the year, you must file an FBAR (FinCEN Form 114) every year. This includes bank accounts, brokerage accounts, mutual funds, and many foreign pension accounts. We prepare and file FBARs for individuals and businesses. We identify all accounts you need to report and make sure everything gets filed on time. If you can sign checks or move money in your employer’s or business’s foreign accounts, we explain what you need to file. Get help with your FBAR filing and compliance.

Offshore Account Planning Strategies

Smart planning for your foreign accounts can reduce how much you need to report and lower your penalty risk. Our international tax specialists help you organize who owns your accounts to make reporting easier. We find accounts that don’t require FBAR filing and help you time when to close or move accounts to keep things simple. If you’re thinking about opening new foreign accounts or changing how your current accounts work, we explain the tax and reporting consequences before you make any moves.

Offshore Asset Reporting (FATCA)

If you have foreign financial assets worth more than $50,000, you must report them on Form 8938 under FATCA. Americans living abroad have higher limits before they need to file. You need to report foreign bank accounts, foreign stocks and securities, ownership in foreign companies, and foreign life insurance policies. Form 8938 gets filed with your tax return. It has different rules than FBAR, which means many people need to file both forms. We figure out which assets you need to report, prepare Form 8938 correctly, and make sure you meet both FBAR and FATCA requirements.

Offshore Asset Structuring

How you own your offshore assets affects what you need to report and how much tax you pay. Our international tax specialists review your foreign investments, business interests, and financial accounts to find the best way to own them. This includes deciding whether your foreign companies should be treated as corporations, partnerships, or disregarded entities for U.S. tax purposes. 

Tax Treaty Benefits

The U.S. has income tax treaties with more than 60 countries. These treaties can lower the tax taken out of your dividends, interest, and royalties. They decide which country can tax specific types of income and stop you from paying tax twice on the same money. Our international tax advisors review the treaties that apply to you and make sure you get all the benefits you qualify for.

Foreign Earned Income Exclusion

U.S. citizens and residents living abroad can exclude up to $126,500 (2024) of income they earn from working in a foreign country. You don’t have to pay U.S. tax on this money if you meet either the bona fide residence test or the physical presence test. When you add the foreign housing exclusion, many Americans living abroad don’t owe any U.S. tax. We make sure you qualify and claim the maximum amount you can exclude.

PFIC Planning

Passive Foreign Investment Company rules create extra taxes for Americans who own foreign mutual funds and similar investments. These rules can make you pay much more tax than you should. Good planning using QEF and mark-to-market elections can reduce the damage. We find PFICs in your investments and use strategies to lower your tax bill.

Foreign Tax Credits

If you pay taxes to a foreign country on income that the U.S. also taxes, you can claim a foreign tax credit. This stops you from paying tax twice on the same money. For Americans living in countries with high taxes, this credit often saves more money than the Foreign Earned Income Exclusion. We look at your complete tax situation to figure out which option cuts your tax bill the most.

Don't Let Offshore 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.

Schedule a Free Consultation Now

Your information is 100% confidential and protected.

Our International & Expatriate Tax Services

We handle all your international tax needs, from filing forms to planning how to lower your tax bill. Our team includes tax attorneys, CPAs, and enrolled agents who specialize in international tax issues.

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 services
  • ✓Report foreign rental income
  • ✓Multi-country tax treaty filing
  • ✓Haven’t filed taxes in years
  • ✓Fix mistakes on tax returns for international reporting errors
  • ✓Overseas bank account reporting

Global Tax Planning Services

  • ✓Green card tax implications
  • ✓Exit tax for expats
  • ✓Foreign earned income exclusion rules
  • ✓Offshore business structuring
  • ✓PFIC tax rules
  • ✓Claim tax treaty benefits
  • ✓Reporting foreign retirement accounts
  • ✓Inheritance from overseas

International Tax Advisory Services

  • ✓IRS notice response for offshore tax penalties
  • ✓Penalty abatement request for reasonable cause
  • ✓Streamlined filing compliance procedures
  • ✓Late FBAR filing
  • ✓IRS voluntary disclosure program
  • ✓IRS offshore account audit
  • ✓IRS appeals process representation

International Tax Consulting Services

  • ✓Foreign investment due diligence
  • ✓International business transactions
  • ✓Starting a business overseas
  • ✓Foreign account tax compliance
  • ✓Expat tax filing

Offshore Account Disclosure: Options for Past Non-Compliance

Most people with foreign accounts don’t know they need to file FBAR or other international tax forms until years later. By then, unfiled years have stacked up and the IRS can charge $10,000 or more per form, per year. You can fix this. Voluntary disclosure programs let you come forward and pay little to no penalty.

IRS Streamlined Filing Compliance Procedures

The Streamlined Procedures work for taxpayers who didn’t know about their global tax filing requirements. This is the most common path for expats and Americans with foreign accounts.

  • Streamlined Foreign Offshore: For taxpayers living outside the U.S. No penalty.
  • Streamlined Domestic Offshore: For taxpayers living in the U.S. The penalty is 5% of your highest foreign account balance.

Both require amended returns for 3 years, FBARs for 6 years, and a statement explaining why you didn’t file.

Delinquent FBAR Submission Procedures

If you reported all your income and don’t owe tax, you may be able to file late FBARs with no penalty. You just need to explain why they’re late.

Voluntary Disclosure Practice

If you knew about your filing requirements and didn’t follow them, the IRS Voluntary Disclosure Practice is still an option. You disclose everything to IRS Criminal Investigation. You’ll pay large penalties, but you avoid criminal charges.

Get help from Silver Tax Group with your unfiled tax returns.

IRS International Tax Reporting Forms We Prepare and Submit

IRS Form When to file What it covers

Form 2555

Download Form 2555 from the IRS 		Claiming the Foreign Earned Income Exclusion and foreign housing amounts Foreign earned income exclusion plus housing exclusion or housing deduction for qualifying taxpayers abroad

Form 1116

Download Form 1116 from the IRS 		Claiming a Foreign Tax Credit for income taxes paid to another country Foreign tax credit calculation and limitation by category of income

Form 8938

Download Form 8938 from the IRS 		Meeting FATCA reporting thresholds for specified foreign financial assets Foreign financial assets such as accounts, foreign stocks and securities, and certain foreign entities held directly

Form 5471

Download Form 5471 from the IRS 		U.S. persons with certain ownership or roles in a foreign corporation Foreign corporation information reporting, including ownership, income, and key schedules for controlled foreign corporations

Form 8865

Download Form 8865 from the IRS 		U.S. persons with certain ownership in a foreign partnership Foreign partnership information reporting, including ownership and partner level items

Form 3520

Download Form 3520 from the IRS 		Transactions with foreign trusts or receipt of large foreign gifts Foreign trust transactions and certain foreign gifts and bequests that require reporting

Form 3520-A

Download Form 3520-A from the IRS 		Foreign trust with a U.S. owner and annual information reporting Annual foreign trust information return for trusts treated as owned by a U.S. person

Form 8621

Download Form 8621 from the IRS 		Holding shares in a Passive Foreign Investment Company PFIC reporting and elections, commonly tied to non U.S. mutual funds and certain offshore investment vehicles

Form 8833

Download Form 8833 from the IRS 		Taking a treaty based return position that requires disclosure Disclosure of how a tax treaty position affects U.S. tax reporting in situations where disclosure is required

Form 2555

Download Form 2555 PDF
When to file
Claiming the Foreign Earned Income Exclusion and foreign housing amounts
What it covers
Foreign earned income exclusion plus housing exclusion or housing deduction for qualifying taxpayers abroad

Form 1116

Download Form 1116 PDF
When to file
Claiming a Foreign Tax Credit for income taxes paid to another country
What it covers
Foreign tax credit calculation and limitation by category of income

Form 8938

Download Form 8938 PDF
When to file
Meeting FATCA reporting thresholds for specified foreign financial assets
What it covers
Foreign financial assets such as accounts, foreign stocks and securities, and certain foreign entities held directly

Form 5471

Download Form 5471 PDF
When to file
U.S. persons with certain ownership or roles in a foreign corporation
What it covers
Foreign corporation information reporting, including ownership, income, and key schedules for controlled foreign corporations

Form 8865

Download Form 8865 PDF
When to file
U.S. persons with certain ownership in a foreign partnership
What it covers
Foreign partnership information reporting, including ownership and partner level items

Form 3520

Download Form 3520 PDF
When to file
Transactions with foreign trusts or receipt of large foreign gifts
What it covers
Foreign trust transactions and certain foreign gifts and bequests that require reporting

Form 3520-A

Download Form 3520-A PDF
When to file
Foreign trust with a U.S. owner and annual information reporting
What it covers
Annual foreign trust information return for trusts treated as owned by a U.S. person

Form 8621

Download Form 8621 PDF
When to file
Holding shares in a Passive Foreign Investment Company
What it covers
PFIC reporting and elections, commonly tied to non U.S. mutual funds and certain offshore investment vehicles

Form 8833

Download Form 8833 PDF
When to file
Taking a treaty based return position that requires disclosure
What it covers
Disclosure of how a tax treaty position affects U.S. tax reporting in situations where disclosure is required

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. 

  • Strategy
  • Intervention
  • Leverage
  • Value
  • Expertise
  • Resolution

Attorney-Client Privilege

When you talk to our attorneys, your conversations stay private because of attorney-client privilege. If you didn’t file correctly in the past, this protection matters. The government can force your accountant to testify against you, but they can’t do this with your attorney. For international tax problems, a tax attorney protects you in ways a CPA can’t.

Deep International Tax Experience

Our team of offshore tax specialists have expertise in filing US taxes overseas. We handle FBAR and FATCA filings, voluntary disclosures, foreign corporation and partnership reporting, expatriate returns, and cross-border planning for clients across the globe. 

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.

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.

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.

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.

See our pricing

Frequently Asked Questions About International Tax Services

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

Yes. If your foreign financial accounts total more than $10,000 at any time during the year, you must file an FBAR (FinCEN Form 114). This includes bank accounts, brokerage accounts, mutual funds, and many foreign pension accounts. You file the FBAR separately from your tax return through FinCEN’s website. If you don’t file, penalties can reach $10,000 per account if you made an honest mistake, or $100,000 or 50% of your account balance if you knew you should have filed.

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. Learn more about FBAR vs Fatca here.

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

You can fix past filing mistakes. The IRS Streamlined Filing Compliance Procedures let you file old tax returns and FBARs with lower or no penalties if you didn’t break the rules on purpose. Americans living abroad pay no penalty. Americans living in the U.S. pay a 5% penalty. If you reported all your income but just didn’t file FBARs, the Delinquent FBAR Submission Procedures might let you file with no penalty. We review your situation and tell you the best way to fix it.

What is the Streamlined Filing Compliance Procedure?

The Streamlined Procedures are IRS programs that let you catch up on international reporting with lower penalties. You file 3 years of tax returns and 6 years of FBARs. You also sign a statement saying you didn’t break the rules on purpose. Americans living abroad pay no penalty. Americans living in the U.S. pay a 5% penalty based on the value of their foreign assets. You can only use these programs if the IRS hasn’t contacted you yet.

Learn more about offshore taxes:

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.

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