International Detection And Enforcement

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For much of banking history, non-U.S. banks have had the ability to maintain the privacy of account holders from the IRS and state taxing authorities. This changed in 2008 when the IRS succeeded in forcing international banks with branches in the U.S. (such as UBS) to disclose offshore accounts held by U.S. citizens. Other governments soon followed suit.

Under foreign bank account reporting (FBAR) rules, if you have a foreign bank account containing more than $10,000 in aggregate at any time during the reporting year, that account information must be reported to the IRS, and any income from that account must be declared on the proper schedule of your tax return.

You must do both — report the account and declare the income. If you fail to report the account or declare the income, you face a possible criminal tax investigation, international tax enforcement, fines, and jail time.

Bank reporting practices affect both U.S. citizens (at home and living abroad) and noncitizen residents:

  • U.S. citizens and noncitizen residents must report income on a U.S. tax return, regardless of where that income was earned.
  • U.S. citizens working overseas must report income to the IRS and, most likely, to the country in which they live and in which they earned the income.

If you have been affected by the foreign bank account reporting (FBAR) rules, and you have been or you expect to be subjected to unreported income recapture by the IRS, you need sophisticated tax law defense.

An international tax dispute attorney from Kundra & Associates is prepared to guide you through an international tax investigation, IRS audit, or criminal tax case resulting from disclosure of a foreign tax shelter.

There May Be No Tax Consequences

Some taxpayers have found after disclosure that the dollar impact was not as massive as they originally feared. You may have paid taxes already to the foreign country. In fact, you may have credit owed to you because the U.S. has a treaty with the other country. You will not know until you work with an attorney who understands international tax enforcement.

If you failed to participate in the IRS voluntary disclosure program, and you are now facing possible criminal tax penalties for a tax haven account, our tax defense lawyers will work to minimize the consequences.

Kundra & Associates aggressively defend clients in criminal tax cases alleging fraudulent tax filings and illegal trusts. Contact an international tax law attorney from Kundra & Associates for a consultation regarding international tax enforcement.