Offshore/Foreign Compliance
Our Offshore/Foreign Compliance Practice Group exists because there are valid, beneficial reasons for overseas investing, and compliance with the strict United States (“U.S.”) Tax Code (“the code”) is necessary to take advantage of any benefits. The challenges and nuances of the code make it necessary to seek skilled counsel. Further, the IRS, Department of Justice (“DOJ”), and various other taxing authorities are much more likely, in this day and age, to catch on to taxpayer negligence or evasion. The U.S. Department of Treasury and Congress recognize that at least $100 billion annual tax from foreign investments goes unpaid. Collection of these taxes is a top priority of the U.S. Government. To remedy the loss, the Department of Justice has devised a well-thought-out attack plan.
The IRS has obtained significant information, by strategically timing various incentives and programs in tandem with the Tax Division's civil and criminal litigation efforts, about those facilitating tax fraud; information that is extremely important to tax administration and will lead to a proliferation of criminal tax investigations.
“We are honored to be recognized for our excellence in this area of law by speaking before the South Korean National Congress and National Tax Service on U.S. Foreign Tax Compliance with Offshore Bank Accounts, FATCA and tax penalty assessment and collection procedures.” –Steve Moskowitz, Founding Partner in Seoul, South Korea, December 2011.
Also See: Offshore Banking, Offshore Planning, Foreign Bank Account Representation, Offshore Voluntary Disclosure, California Voluntary Disclosure Initiative, Foreign Account Tax Compliance Act (FATCA), Passive Foreign Investment Companies, QEF Elections, Making a Mark-to-Market Election, Controlled Foreign Corporations,