International Tax Law | Tax Attorneys in Roseville, CA

U.S. International Tax Obligations

The United States taxes its citizens and permanent residents on worldwide income, regardless of where they live or where the income is earned. This means that U.S. persons with foreign income, foreign investments, or foreign business interests have significant tax reporting obligations that extend well beyond a simple domestic return.

Failure to meet international tax and reporting requirements can result in civil penalties that are far larger than the underlying tax owed — and in cases of willful non-compliance, criminal prosecution.

FBAR and FATCA Compliance

U.S. persons with foreign financial accounts must comply with two distinct reporting regimes:

FBAR (FinCEN Form 114): Required when the aggregate value of all foreign financial accounts exceeds $10,000 at any point during the calendar year. Filed annually with FinCEN, the FBAR is separate from a federal income tax return. Willful failure to file can result in penalties of up to 50% of the account balance per year.

FATCA (Foreign Account Tax Compliance Act): Requires U.S. taxpayers to report specified foreign financial assets on Form 8938 (Statement of Specified Foreign Financial Assets) when asset values exceed applicable thresholds. FATCA also requires foreign financial institutions to report U.S. account holders to the IRS.

International Business Taxation

U.S. businesses with international operations face additional complexity, including transfer pricing rules that govern transactions between related entities, Subpart F income provisions that can accelerate taxation on certain offshore income, and the Global Intangible Low-Taxed Income (GILTI) regime applicable to U.S. shareholders of controlled foreign corporations (CFCs). Our attorneys help businesses structure international operations in a tax-efficient and compliant manner.

Coming Into Compliance

For taxpayers who have not met their international reporting obligations, several pathways exist to come into compliance, including the IRS Voluntary Disclosure Program, the Streamlined Domestic Offshore Procedures, and the Streamlined Foreign Offshore Procedures. Selecting the right path depends on the nature of the non-compliance and whether violations were willful.