Focus on your priorities. We’ll handle the international tax resolution process.
From international tax compliance concerns to disputes, we help you navigate complex rules and avoid serious consequences.
Whether you live abroad or not, the IRS is able to track your income earned overseas, as well as assets held in foreign bank accounts. If you mistakenly or intentionally forget to disclose foreign income, bank accounts, or other assets, international tax law experts can help you resolve your issue.
Our international tax attorneys have the expertise to guide you through a diverse range of international tax law matters. We understand the complex issues that arise when living or transacting business overseas. With a personalized, attentive, client-first approach, we deconstruct your unique international tax situation and offer guidance and support based on US tax laws and regulations.
When two or more jurisdictions pursue the same tax transactions or activities, disputes arise over which have precedent. Tax treaties are able to resolve most disputes and cases of double taxation, but not all.
Our tax lawyers have extensive experience representing taxpayers abroad and resolving disputes, including:
In an International Tax Audit, the IRS contacts you to acquire penalties for unreported income and non-reporting of offshore accounts and/or assets.
To guide you through an international tax audit’s complex maze of foreign tax procedures and policies, you need reliable, expert legal representation.
Wiggam Law international tax lawyers can assist with defense against IRS overseas penalties, statute of limitations and international transactions.
The IRS continues to increase forces against international tax fraud or evasion. Tax evasion is a serious crime penalized by monetary fines and prison sentences.
International tax laws can be confusing and overwhelming, causing taxpayers to misunderstand necessary procedures and filings. Wiggam Law tax attorneys are prepared to defend your case against international tax fraud.
Every individual taxpayer’s situation is unique. The tax lawyers at Wiggam Law take the time to listen to your specific international tax compliance issue.
We gather information, paperwork, forms and filings in order to create a strategic defense that will give you the best solution for your situation through detailed research, strategic evaluations, and experienced execution.
By federal law, U.S. citizens have the responsibility to report any and all foreign income and some assets to the IRS. In addition to filing all applicable forms, you may be required to file:
The Report of Foreign Bank and Financial Accounts (FBAR) is not a tax return, but instead an information report that is meant to deter tax evasion. The FBAR is required if:
You will need to file the FBAR in addition to all other relevant filing requirements.
Whether non-compliance was a mistake or something purposefully executed, the IRS can apply severe penalties if you have undisclosed foreign bank accounts.
Depending on your circumstances, the penalty for an undisclosed foreign bank account can be up to $250,000 or five years in jail, or both. The IRS takes offshore tax evasion seriously and even mistakes can be harshly punished. They continue to strengthen global efforts to improve the exchange of foreign account information with over 100 nations.
The IRS defines International Tax Fraud as: “Any person who willfully attempts in any manner to evade or defeat any tax imposed by this title or the payment thereof shall, in addition to other penalties provided by law, be guilty of a felony and, upon conviction thereof, shall be fined not more than $100,000 ($500,000 in the case of a corporation), or imprisoned not more than 5 years, or both, together with the costs of prosecution.”
As with any tax issue, the best method of resolution for international tax compliance issues is to take action towards getting back into compliance with the IRS. There are three main options available:
International tax attorneys can help you thoroughly review each option to understand which program you’re qualified to participate in and which program is the most appropriate for your situation.
In order to qualify for the IRS Streamlined Filing Compliance Procedures, you must verify that you did not wilfully fail to file or pay your taxes. You’re not eligible for the Streamlined Filing Compliance Procedures if you have previously been investigated by the IRS.
The Offshore Voluntary Disclosure Program Voluntary Disclosure Program was a program that offered protection from criminal liability and allowed terms for resolving civil tax and penalty obligations if you failed to report foreign assets to avoid paying taxes. The program is no longer available. Individuals who wish to come forward voluntarily to disclose their potentially criminal activity can do so through the standard Voluntary Disclosure Program.
Under the Voluntary Disclosure Program, taxpayers can work with the IRS to disclosure their activity and pay taxes and penalties, in lieu of criminal enforcement.
To qualify for the Delinquent FBAR Submission Procedures, you must properly report your foreign accounts on your tax returns and pay the appropriate tax. If you did not file the required Report of Foreign Bank and Financial Accounts (FBAR), you may qualify to submit the delinquent FBARs without penalty. Note that if you don’t file or take advantage of this submission process in a timely manner, you can face severe FBAR penalties.
Delinquent International Information Return Submission Procedures.
If you can exemplify reasonable cause as to why you did not file the appropriate returns, you may be able to qualify for the Delinquent International Information Return Submission Procedures.
If you do not qualify for the Voluntary Disclosure Program or Streamlined Filing Compliance, you can use the Delinquent International Return if you:
“I consulted Wiggam Law about an issue with my international employer and Georgia income tax liability. They gave me some excellent and nuanced advice, based on some research they undertook, for a very reasonable fee. I will certainly use their services again if an issue like this comes up again.”
-Wayne Stargardt
Reach out to Wiggam Law today. Call 404-233-9800 or contact us:
