International Tax Compliance
K&F regularly represents both U.S. individuals and entities seeking advice on how to maintain compliance or become compliant with U.S. tax reporting obligations for assets and accounts that are held overseas, and non-U.S. persons and entities owning U.S.-based assets. K&F attorneys work closely with our clients’ accountants to ensure reporting requirements are fulfilled in a way that minimizes the risk of audit or the imposition of penalties by the IRS.
Attorneys at the firm are experienced in assisting clients in identifying when and how they should file a Report of Foreign Bank and Financial Accounts (FBAR) and other foreign information returns, as well as the proper reporting of non-U.S. source income.
K&F attorneys also assist clients in determining how to classify non-U.S. entities for purposes of Foreign Account Tax Compliance Act (FATCA) reporting.
At times, K&F attorneys may advise clients to make a voluntary disclosure to the IRS and/or state taxing authorities. Voluntary disclosures can be an effective way for taxpayers to limit their criminal and civil liability for past tax noncompliance, including failure to file tax returns or international forms and other tax and reporting violations.
K&F attorneys are well-acquainted with the IRS’s traditional disclosure practice, the former Offshore Voluntary Disclosure Program, and all recent developments. The firm has also represented thousands of taxpayers coming into compliance under alternative paths, including the Streamlined Filing Procedures, FBAR Submission Procedures, Delinquent International Information Return Submission Procedures, Qualified Amended Returns, and simply filing amended returns pursuant to the IRS compliance policy statements.
Advice regarding international tax compliance often goes hand-in-hand with estate and tax planning advice offered by K&F attorneys.