Common questions, answered in full.

You can expect experienced, thoughtful guidance, clear communication, and careful attention to the details of your situation. We take our responsibility to our clients seriously, protect the confidentiality of your information, respond promptly, and make sure you understand both the issues you face and the options available to you.

In some cases, yes. Depending on your circumstances, we may be able to reduce penalties, challenge an incorrect assessment, or pursue resolution options that allow qualifying taxpayers to settle for less than the full amount owed. We cannot guarantee a reduction, but after reviewing your case, we will tell you clearly which options are available and what outcome we believe is realistically achievable.

Generally, yes. U.S. citizens are subject to U.S. tax reporting on their worldwide income even when they live abroad full-time, although filing requirements depend on your income and circumstances and provisions such as the Foreign Earned Income Exclusion or foreign tax credits may reduce or eliminate the U.S. tax you owe.

Generally, yes. U.S. taxpayers must report taxable income from worldwide sources, and certain foreign financial accounts and assets may also require additional reporting, such as an FBAR or Form 8938, depending on the type and value of the assets and your individual circumstances.

Yes. We can review the notice and your prior filings, determine what triggered the penalty, and evaluate your options for responding or requesting penalty relief when appropriate. Because international information-reporting penalties can be substantial and response deadlines matter, we recommend addressing an IRS notice promptly.

Yes. Becoming a U.S. tax resident can create new reporting requirements for your worldwide income and certain foreign financial accounts and assets, even if you owned them before moving to the United States. We can help determine which U.S. tax and information-reporting rules apply to you and make sure your foreign income and assets are reported correctly.

A Passive Foreign Investment Company (PFIC) is generally a foreign corporation that meets certain passive-income or passive-asset tests; many foreign investment funds can fall into this category. U.S. taxpayers who own PFICs may have special tax calculations and may need to file Form 8621 for each PFIC, so these investments should be identified and reviewed carefully.

Yes. A foreign inheritance may create U.S. information-reporting requirements even when the inheritance itself is not subject to income tax, and failure to file required forms such as Form 3520 can result in significant penalties. We can review the inheritance and your prior filings, represent you during the IRS examination, and determine the best way to correct any reporting deficiencies and address potential penalties.

A tax treaty is an agreement between the United States and another country that may determine which country has the right to tax certain income or provide reduced tax rates or exemptions. Whether a treaty applies depends on factors such as where you live, your tax residency or citizenship, the country involved, and the type of income you receive; we can review your circumstances and determine whether treaty provisions may benefit you.

A Controlled Foreign Corporation (CFC) is generally a foreign corporation that is more than 50% owned, by vote or value, by certain U.S. shareholders. If you own an interest in a foreign company, CFC rules can create significant U.S. tax and reporting requirements — including Form 5471 and, in some cases, U.S. tax on certain corporate income even if no money was distributed to you.