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International Tax

EXPERIENCED IN INTERNATIONAL TAX MATTERS

In today’s global marketplace companies and individuals engaging in overseas business transactions and financial activities must navigate complex and challenging tax issues.  If you need an international tax attorney, Thorn Law Group represents clients in Virginia, across the country and around the globe in sophisticated tax law matters.  We help businesses and individuals resolve all types of international tax problems, such as:

Anti-Money LaunderingFinancial institutions, banks and other entities are required under the law to prevent, identify and report money laundering activities.  In the United States, financial institutions have a legal obligation to report suspicious activity through the filing of a suspicious activity report (SAR) with the Financial Crimes Enforcement Network (FinCEN). Many other nations around the world also require institutions to report suspicious financial transactions to a designated intelligence unit within their respective country.

Foreign Corrupt Practices ActThe Foreign Corrupt Practices Act (FCPA) generally prohibits companies from making bribes or other corrupt payments to foreign officials in order to assist in obtaining or maintaining business.  The anti-bribery provisions of the FCPA apply to all U.S. persons and certain classes of foreign issuers of securities, as well as foreign firms and persons who directly or indirectly through agents take any action in furtherance of a corrupt payment within the United States.

International Banking LawAs a result of the U.S. government’s investigation into the actions of UBS AG, international banks have once again been placed into the public spotlight. Thorn Law Group represents foreign banks and financial institutions in disputes with the United States government as well as individuals and entities who are involved in private disputes with foreign banks.

Foreign Account Tax Compliance ActUnder The Foreign Account Tax Compliance Act (FATCA), U.S. taxpayers with foreign financial assets are required to report information about their assets on Form 8938.  Taxpayers who fail to report foreign financial assets and accounts on Form 8939 are subject to a $10,000 penalty for each year they are not in compliance with the Act.  Foreign financial institutions are also required to report information to the IRS about financial accounts held by U.S. taxpayers, or entities in which U.S. taxpayers hold a substantial ownership interest.

International Tax Disputes.  The Internal Revenue Service has placed a high priority on identifying and pursuing international tax violations.  The IRS is using both civil audits and criminal investigations and prosecutions to combat these tax violations.  By increasing cooperation and expanding information-sharing programs with nations around the world, the IRS has been able to launch an aggressive initiative to uncover U.S. taxpayers with unreported foreign bank accounts.

Offshore Voluntary Disclosure Programs.  Tax evasion associated with offshore accounts and assets is a top enforcement priority for the IRS.  In an effort to encourage taxpayers with undisclosed foreign accounts to voluntarily come forward and disclose their accounts, the IRS established its first Offshore Voluntary Disclosure Program (OVDP) in 2009. The IRS has made several revisions and modifications to OVDP since this time and the most recent changes to the program were announced in June 2014.  These modifications expand eligibility for participation in the IRS streamlined filing compliance program and include new requirements for taxpayers who acted willfully to hide their offshore accounts from the U.S. government.

To learn more about the international tax law practice at Thorn Law Group or to discuss your situation with an international tax attorney at our firm, contact our Virginia satellite office at 703-752-3752 or email managing partner Kevin Thorn at ket@thornlawgroup.com.


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