Foreign Bank Accounts and Offshore Tax Compliance

The Internal Revenue Service and the Department of Justice have increased government enforcement related to foreign bank accounts and offshore tax evasion.  U.S. tax laws require that each U.S. person who has a financial interest in, or signature authority over, one or more accounts in a foreign country, with the aggregate value of $10,000 or more, must file a Report of Foreign Bank and Financial Accounts (FBAR).  Additional reporting requirements relate to foreign corporations, foreign trusts, foreign gifts, foreign inheritances, and specified foreign financial assets.

Failure to report foreign bank accounts, offshore assets, or unreported foreign income can lead to a possible criminal prosecution and significant civil penalties. Former IRS Attorneys of Holtz, Slavett & Drabkin have years of experience representing clients with issues related to offshore tax compliance and foreign bank accounts. We have represented numerous clients in the IRS Offshore Voluntary Disclosure Programs, IRS Streamlined Filing Compliance Procedures, Delinquent FBAR Submission Procedures, and Delinquent International Information Return Submission Procedures–successfully resolving their FBAR and other offshore compliance issues. We also represent clients who are being audited by the IRS for potential violations of FBAR rules, or who are being criminally investigated by the Department of Justice for the alleged failure to report offshore income or accounts.

Our tax attorneys can assist clients with developing the appropriate strategy about FBAR compliance and providing vigorous defense before the IRS or the Department of Justice.