The Firm’s work and services in the area of U.S. Foreign Compliance and Reporting embodies its longstanding commitment to serving both U.S. clients with international assets as well as International Clients on a wide range of matters including tax planning, ongoing tax compliance, and voluntary disclosure of unreported foreign income, assets, entities, and trusts.   

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Starting in the early 2000’s and rapidly expanding during the period 2005 – 2007, the IRS, Treasury Department, and the Department of Justice greatly expanded their enforcement actions on the U.S reporting obligations for U.S. Persons with interests in foreign trusts, entities and financial accounts. These expanded enforcement activities against perceived and actual tax evasion, reporting and compliance evasion, and non-compliance, resulted in a number of initiatives and programs by the IRS to press for compliance while providing an opportunity to bring recalcitrant U.S taxpayers into compliance.

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Though the IRS OVDI and OVDP programs of the 2007 – 2018 reporting era have ended, the laws and regulations regarding U.S. reporting for foreign assets, entities, and trusts remain in effect, and reporting and compliance matters in this area continue to develop.  Given the complexity of these laws and the significant penalties for reporting lapses and errors, reporting requirements remain relevant for both recalcitrant taxpayers and for individuals and families with U.S. contacts and/or those contemplating planning and estate structures which give rise to U.S. reporting requirements. 

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Accordingly, the objectives, planning needs, and circumstances of each client within this Practice Area are unique, highly sensitive, and often involve substantial monetary value. Undertaking these complex matters and advising in these unique situations requires an expert knowledge of applicable U.S. federal law and the intricacies of navigating a multi-faceted framework of tax law, regulations, initiatives and programs.