Many people who have established or inherited bank accounts outside of the United States, or hold ownership interests in foreign corporations, trusts or other entities, are not aware of the myriad reporting requirements imposed under U.S. law such as Form TD F 90-22.1 (commonly known as the FBAR), Form 3520, Form 3520-A, Form 5471 and most recently Form 8938. Because these reporting obligations are enforceable by substantial civil and criminal penalties, many who have not complied in the past are uncertain how to rectify their situation.
Our tax attorneys can help you understand your options and navigate the appropriate procedures. The IRS has instituted a voluntary disclosure program under which qualifying individuals with previously unreported foreign accounts and assets may come forward without the fear of criminal exposure and with predictable payment amounts. As part of this process, we can also assist you restructure or unwind foreign entities for greater U.S. tax efficiency.