US CPA Partner for Foreign Tax and Accounting Firms

Yes, the IRS offers a variety of methods for US taxpayers to fix their foreign income and asset reporting. Common programs include the former Offshore Voluntary Disclosure Program (OVDP) and related programs, such as the Streamlined Filing Compliance Procedures. We have an extensive history and background with these programs. We have helped clients and their foreign tax advisors navigate all versions of these programs since 2009!

To assist you and your client, we review the client’s case facts and circumstances. Then, we advise you and your client on the options available. We explain the IRS programs or other methods you can use to correct the situation, as well as the important considerations and costs. We help you understand the benefits and risks of each option. We also advise you on what we recommend. Next, we support you through the process and prepare the original or corrected filings.

We hear this question all the time! While it is possible that the IRS may never find out, ignoring the US requirements comes with very high risk.

Governments around the world are sharing more and more information on their residents and taxpayers. The Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standard (CRS) already lay the foundation for such sharing. In addition, the IRS has begun using data analytics to identify possible cases of non-reporting.

Individuals who don’t file US tax returns and informational reports already may face large fines ($10,000-$100,000) per form required in their tax returns. If the IRS determines that the individual was aware of the requirements and did not file, then the consequences are even worse. These “willful” non-filers are not able to claim reduced penalties under the IRS amnesty programs. In addition, they may face criminal charges. Plus, the statute of limitations remains open, so it doesn’t matter how many years go by—the IRS can still look at old cases and levy penalties. These certainly aren’t risks that we would recommend any client take!

Your client could give up his or her green card or US citizenship. But this is a big decision—and one that should be carefully planned from both tax and immigration perspectives. On the tax side, we can help you file specific forms in order to end the tax obligations. Remember, it’s not enough for your client to give up US citizenship or a green card. Instead, your client must certify to the IRS that the last five years of tax returns are accurate and have been filed with the IRS. In addition, your client may be subject to an “Exit Tax” on his or her net worth.

We can help you by:

• Explaining the tax impacts of giving up US citizenship or a green card
• Reviewing prior filings for accuracy
• Assisting with tax planning to reduce the Exit Tax
• Preparing proper filings and calculations for the Exit Tax
• Explaining the US tax filing requirements for the years after your client gives up US citizenship

We typically work alongside tax attorneys who will advise you on the proper structure for your US investments regardless of whether they include real estate or personal property. If income, gift, or estate tax returns are required, we can prepare these for your client on an as-needed basis. If there are informational returns required, such as IRS Form 5472 (foreign-owned disregarded US entity) or withholding forms, such as Form W8-BEN, W8-BEN-E, or 8288-B, we can prepare these, as well.

Yes. We work with clients from all over the world who are interested in doing business with the US. We can assist your client in multiple ways.

• We can help determine whether the foreign company itself should be operating in the US or whether a separate US entity should be established.
• If establishing a US entity makes sense, we can help your client select the best type of US entity and tax structure to optimize its tax efficiency.
• We can also help your client choose the best US state to establish its business in and help determine the state filing requirements.
• We can ensure that all tax returns and estimated tax payments are made timely.
• We can help with any transfer pricing considerations.
• If your client has any individual filing requirements, in addition to the entity filing requirements, as a result of doing business in the US, we can help with these personal filings, as well.

We offer pre-immigration tax planning for individuals. We can conduct a thorough review of their foreign financial assets and income before becoming a US taxpayer. We can then advise the employees on ways to reduce or consolidate their foreign financial assets, danger zones for foreign income (example – PFICs), and other related areas that may cause significant headaches when filing tax returns.

Yes, we can. The IRS announced on July 19, 2019, a new International Campaign for Expatriation and IRS Form 8854. As this area is now under heavy scrutiny, there should be extra due diligence given to a client’s facts and circumstances as it applies to IRC 877A. We have been preparing these forms since the new version of IRC 877A came into being in 2008. We have extensive experience with this code section and Form 8854.