The IRS is aggressively targeting unreported offshore accounts and foreign tax shelters. We help clients understand their reporting obligations, including FBAR and FATCA, and provide legal defense for those with undisclosed accounts. If you're concerned about foreign trust structures, inheritance through offshore accounts, or other complex holdings, we can guide you through IRS scrutiny and disclosure strategies—strictly from a tax compliance and defense perspective. 

U.S. persons must report foreign financial accounts over certain thresholds. Failure to file can result in steep civil and criminal penalties. We help clients meet reporting obligations and correct past errors through proper disclosure strategies.

The IRS offers programs for taxpayers to come into compliance without facing the harshest penalties—if they act before being contacted by authorities. We guide clients through the Offshore Voluntary Disclosure Practice (Form 14457), streamline procedures for non-willful violations, and help gather the documentation needed to reduce financial and criminal risk.

The IRS has increased enforcement against high-net-worth individuals with global assets. These audits are invasive and complex. We build proactive defense strategies and manage audit responses. 

Renouncing citizenship or returning to the U.S. can trigger an Exit Tax or other reporting obligations, especially for high-net-worth individuals. We help clients calculate potential liabilities, manage compliance under the Expatriate Act, and structure their transitions to avoid future penalties or enforcement complications. 

Foreign businesses operating in the United States face complex and overlapping tax obligations. We help international companies understand and comply with U.S. tax law, including issues related to income, employment withholding, transfer pricing, and excise taxes. Our team advises on entity structure, treaty benefits, and strategies to avoid double taxation while maintaining proper reporting standards and compliance with IRS and state authorities.

Whether through gifts, inheritance, or foreign corporations, undisclosed interests can trigger IRS penalties. We help clients meet Form 5471 requirements and other disclosure rules.

If you owe more than $62,000 in back taxes, the IRS can certify your debt to the State Department—leading to passport denial or revocation. We work quickly to reverse this status by negotiating repayment agreements, filing offers in compromise, or addressing errors in IRS records before travel plans are disrupted.