Stein Sperling’s tax attorneys remain at the forefront of developments in international tax enforcement, including as they relate to Foreign Bank Account Reporting (FBAR).

The IRS is fighting offshore tax avoidance through demands for greater international financial transparency. It continues to step up efforts to identify assets that U.S. business and individual taxpayers may be concealing overseas. With certain exceptions, each U.S. citizen or resident with signature authority over one or more foreign bank accounts has an annual obligation to file a Foreign Bank Account Report (FBAR) by October 15. Unfortunately, many taxpayers are unaware of this requirement and face staggering financial losses from back taxes, penalties and interest or even possible criminal exposure for failing to file an FBAR and/or failing to report foreign income.

Our attorneys have substantial experience in tax matters related to offshore assets. We are well-versed in FBAR requirements and related voluntary disclosures that allow taxpayers to avoid criminal sanction in most cases and face reduced but still significant penalties. We assist clients in addressing previously neglected FBAR obligations and in negotiating penalties.