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 improve your tax efficiency.
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International tax rules are complex, and the penalties can be significant for noncompliance. For a nonwillful failure, the penalty generally applies on a per-report basis rather than separately for each account. In appropriate circumstances, the reasonable-cause exception may help prevent a nonwillful penalty when the statutory requirements are satisfied.
If you have foreign income, offshore accounts or international business interests, you need international tax lawyers who can evaluate your circumstances and help you take the appropriate steps to resolve prior filing gaps. Our team can determine what needs to be reported, which years require correction and which compliance procedures apply.
If your concern involves foreign accounts, FBAR penalties, offshore disclosures or IRS tax controversy, you need an experienced counsel to help you develop a strategy tailored to your circumstances.
At Silver Tax Group, we can help you:
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. This means 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.
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.
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.
If you own foreign bank accounts, investments, retirement accounts or real estate held through certain foreign entities, you may have additional reporting obligations. 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.
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 nonresident to resident status creates complications, especially with assets you owned before becoming a U.S. resident.
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.
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.
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.
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.
A U.S. person generally must file an FBAR when foreign financial accounts exceed $10,000 in aggregate during the calendar year. Reportable accounts include bank accounts, brokerage accounts, mutual funds and certain pension accounts. We identify reportable accounts, evaluate applicable ownership and prepare FBARs on time. If you can sign checks or move money in your employer’s or business’s foreign accounts, we also explain what you need to file for accurate FBAR filing and compliance.
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 determine 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.
Depending on your filing status and where you live, you may need to report specified foreign financial assets on Form 8938 once they exceed the applicable FATCA threshold. 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 from 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.
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.
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.
For tax year 2026, qualifying individuals working abroad may be able to exclude up to $132,900 of foreign earned income. Eligibility depends on your foreign tax home and whether you meet the bona fide residence test or physical presence test. We make sure you qualify and claim the maximum amount you can exclude.
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.
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.
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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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.
We help protect you and your business from severe financial penalties. Our international tax compliance services focus on strict adherence to IRS reporting mandates for foreign entities and assets. We are highly capable of handling complex entity reporting and providing guidance to prevent automatic IRS penalties.
Trust us for:
Expatriates are expected to report and pay taxes on their worldwide or local foreign income, depending on their home country’s citizenship-based tax rules and their resident status in their host country. We handle complex mandatory filings such as FBAR and FATCA and correct mistakes on prior tax returns related to international reporting.
Our team can help you with:
International tax planning legally helps minimize your global tax liabilities while maintaining compliance with cross-border regulations. We offer strategies for preserving and structuring your wealth.
Our capabilities include advising on:
We provide proactive guidance for business structuring, cross-border investments and real estate. Our legal team helps you understand complex cross-border laws to reduce the risk of double taxation and other costly penalties while meeting strict reporting duties.
Our strategies include:
Whether you want to set up a business abroad or need help with expat tax filing, trust us for legal and tax guidance. Our team can help assess risk, handle voluntary disclosure programs (VDPs) and resolve unfiled return issues while ensuring full foreign account tax compliance before IRS issues arise.
Partner with us for proactive business and investment guidance about:
Most people with foreign accounts don’t know they need to file FBAR or other international tax forms until years later. When several filing years have passed, the right correction strategy is critical. Potential penalties depend on the form, tax year, facts, reasonable-cause position and whether the conduct was nonwillful or willful.
Our international tax attorneys help you review your facts, assess reasonable-cause arguments and evaluate the risk so you can choose a compliant path. Available correction paths can include:
The Streamlined Filing Compliance Procedures may be available to eligible individual taxpayers, including certain estates, who can truthfully certify that their reporting failures resulted from nonwillful conduct. If you are unsure whether your conduct qualifies, legal guidance is crucial before you file.
Eligible taxpayers who meet the applicable nonresidency requirements are not subject to penalties for failure-to-file, failure-to-pay, information-return, accuracy or FBAR. Since previously assessed penalties are not automatically removed, careful review is essential before filing.
Eligible U.S. residents generally pay a Title 26 miscellaneous offshore penalty equal to 5% of the highest aggregate year-end value of covered foreign financial assets during the applicable disclosure period. Our attorneys can help determine which assets are included in that calculation.
Both SFOP and SDOP can provide eligible taxpayers a structured path to correct prior U.S. tax and foreign-account reporting failures. Generally, the submission involves three years of delinquent or amended income tax returns, six years of delinquent FBARs, payment of applicable tax and interest, and a detailed certification establishing that the conduct was nonwillful.
If you reported your foreign-account income but missed required FBAR filings, you may still have a path to correct the issue. However, the facts and reasonable-cause position should be evaluated carefully before filing, as penalty relief is no longer something taxpayers should assume following the removal of the former public guidance for the Delinquent FBAR Submission Procedures in 2026.
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 the IRS Criminal Investigation. You’ll likely pay significant penalties, but a timely and complete voluntary disclosure may reduce the risk of criminal prosecution.
| IRS Form | When to file | What it covers |
|---|---|---|
Form 2555Download 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 1116Download 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 8938Download 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 5471Download 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 8865Download 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 3520Download 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-ADownload 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 8621Download 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 8833Download 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 |
Work with an international tax attorney who can give you access to legal and financial guidance under one roof. Our managing partner, Chad C. Silver, brings solid experience in law, tax and accounting to approach international tax matters from multiple perspectives.
His admission to the U.S. Tax Court and the State Bar of Michigan, plus his memberships in NATP and ABA, mean you’re working with an authorized professional who can legally represent you in trials, protects your private information and follows strict ethical rules.
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.
Have questions about international tax and our service? We’ve answered some of the questions clients ask most often to help you save time.
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.
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.
You can fix past filing mistakes. The IRS Streamlined Filing Compliance Procedures let eligible taxpayers file three years of amended or delinquent tax returns and six years of FBARs with lower or no penalties if there was nonwillful conduct. If they meet the applicable streamlined procedure requirements, Americans living abroad pay no penalty, while Americans living in the U.S. pay a 5% penalty. If you reported all your income but just didn’t file FBARs, you may be able to file with no penalty depending on the cause. We review your situation and tell you the best way to fix it.
CPAs can be forced to testify against their clients if the IRS investigates past noncompliance. Tax attorneys protect client disclosures and have the legal authority to negotiate penalties and litigate directly in U.S. Tax Court. We offer attorney-client privilege to help protect your confidential disclosures, while our legal authority allows us to represent clients in IRS disputes and U.S. Tax Court matters.
Foreign banks and international financial institutions are legally required to automatically report U.S. account holders’ data and balances directly to the IRS. Hiding assets is no longer possible.
If you missed filing an FBAR, do not assume you can simply file late and receive automatic penalty relief. After Bittner v. United States, nonwillful FBAR penalties generally apply per deficient annual report, not per account.
In addition, the removal of the former Delinquent FBAR Submission Procedures webpage makes the late-filing strategy more fact-specific. Our tax attorney can help you determine whether reasonable-cause filing, Streamlined Procedures, voluntary disclosure or another correction path is the safest option.
Yes, an attorney can help even if the IRS is already investigating. Once the IRS initiates contact, standard amnesty programs are usually off the table. Hiring a tax law firm helps you establish an audit defense, negotiate penalty abatements and prevent criminal escalation.
Our attorneys utilize the Foreign Earned Income Exclusion and Foreign Tax Credits to minimize global tax liability.
Explore these additional resources to learn more about FBAR penalties, foreign asset disclosure and expat tax planning.
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. Call us at 855-900-1040 or contact us online to get expert assistance.
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