Under federal law, U.S. taxpayers, whether residing in the U.S. or abroad, are required to disclose their offshore accounts to the federal government annually. While there are minimum account value thresholds, these thresholds will be easily surpassed in most cases. In this article, Texas international tax attorney Lawrence Brown provides […]
Category: International tax issues
For large business and international taxpayers, filing a return with the Internal Revenue Service (IRS) will frequently lead to post-filing scrutiny. This scrutiny can take a variety of forms, from informal inquiries to invasive audits and criminal tax investigations. When facing post-filing scrutiny (or the risk of post-filing scrutiny), a […]
The Internal Revenue Service (IRS) offers a variety of options to large business and international taxpayers that need to resolve tax controversies at the pre-filing or pre-audit stage. These options are specifically tailored to taxpayers that fall under the jurisdiction of the IRS’s Large Business and International (LB&I) Division, which […]
High-income and high-net-worth U.S. taxpayers who have assets held overseas have an obligation to report these assets to the U.S. Treasury Department. Specifically, taxpayers must report their offshore accounts to the Treasury’s Financial Crimes Enforcement Network (FinCEN), and they must report their “foreign financial assets” (which include offshore accounts) to […]
Taxpayers who own qualifying offshore accounts and other foreign financial assets have an obligation to disclose these assets to the federal government on an annual basis. As we move into 2024, it is important for high-income and high-net-worth taxpayers to ensure that they have a clear understanding of their reporting […]
In a recent news release, the Internal Revenue Service (IRS) announced that it intends to shift its focus to targeting wealthy individuals and business partnerships beginning in fiscal year (FY) 2024. The news release also identifies three specific “priority areas” in which the IRS intends to focus its enforcement efforts […]
U.S. taxpayers who own offshore accounts and certain other foreign financial assets have an obligation to disclose these assets to the Internal Revenue Service (IRS)—provided that their value exceeds the IRS’ relatively modest reporting thresholds. Depending on the nature of a taxpayer’s foreign financial assets, this may entail two separate […]