It is not illegal for U.S. citizens to have foreign bank accounts. There are many legitimate reasons for a U.S. taxpayer to maintain a foreign bank account, including confidentiality, portfolio hedging and asset protection.
However, U.S. taxpayers who have offshore or foreign accounts must adhere to certain requirements. They must report the existence of these accounts as well as income from these accounts on their U.S. income tax returns. They must also declare any offshore or foreign bank accounts over which they have signature authority, regardless of whether they receive any income from the account.
For many years, numerous taxpayers holding offshore or foreign bank accounts have not disclosed the existence of accounts or claimed income from them on their income tax returns. These taxpayers felt comfortable that the U.S. government could not obtain information about their accounts from foreign financial institutions.
Recently, things have changed.
The IRS and the U.S. Department of Justice have focused a great deal of effort on offshore compliance and pursuing criminal and civil penalties against individuals who have not disclosed the existence of their offshore accounts or reported the income from these accounts.
This is especially evident in the number of civil and criminal investigations widely covered in the media, including the ones listed below:
- U.S. investigation of HSBC
- U.S. investigation of Swiss banking giant UBS
- German investigation of Credit Suisse
It is a top priority of the current administration in Washington, D.C. to capture the revenue lost to the Federal government through the use of and non-reporting of offshore accounts and the income derived from them. The IRS has increased the number of audits in this area and is hiring more staff with expertise in international tax investigations. Legislation has been passed and is pending in both the House and the Senate that would provide tools to help increase the ability of the IRS to enforce these tax laws.
At Brown, PC, we have a comprehensive understanding of the rapidly changing laws and policies that affect people with substantial monetary holdings and assets in the U.S. and overseas. With offices in Dallas-Fort Worth, Texas, and Washington, D.C., our nationwide practice is dedicated to protecting the rights of these individuals. We are focused on bringing your offshore bank accounts into compliance with government regulations while minimizing the potential consequences you may face. We represent clients across the United States- from Boston to Atlanta to Los Angeles - as well as American citizens who live and work abroad.
Contact an Offshore Account Compliance Lawyer
If you have an offshore account that you have not previously disclosed to the IRS, we urge you to contact our law firm for a confidential consultation with a lawyer. Please call attorney Lawrence Brown of Brown, PC, toll free at 888-870-0025 or contact us online.Print this Page