International Tax Services for U.S. Taxpayers Abroad and at Home

U.S. tax follows the person, not the address. A citizen or green-card holder who lives in Bogotá, Lisbon or Dubai still files a U.S. return on worldwide income; a resident of Miami who keeps a savings account, a pension or a small company in another country still reports it. The rules are not obscure, but they are unforgiving: the information returns carry fixed penalties whether or not tax was due, and most people who contact me discovered the obligation years after it started.

I concentrate my practice on exactly this: helping U.S. taxpayers with foreign accounts, foreign entities, foreign trusts and foreign investments come into compliance and stay there. I have represented clients in international matters such as FBAR, OVDI and Streamlined Filing since 2009.

What the work covers

Foreign accounts: FinCEN Form 114 (FBAR) and Form 8938 (FATCA), including delinquent filings and the choice between the delinquent-submission procedures and a streamlined submission.
Streamlined Filing Compliance Procedures: the domestic and foreign tracks, the non-willfulness certification (Forms 14654 / 14653), the three amended returns and six FBARs, and the 5% penalty computation where it applies.
Foreign corporations and partnerships: Forms 5471, 8865 and 8858, Subpart F and GILTI, Section 962 elections, dormant-entity filings.
PFICs: identifying foreign mutual funds and ETFs that are passive foreign investment companies, Form 8621, and the excess-distribution, QEF and mark-to-market regimes.
Foreign trusts and gifts: Forms 3520 and 3520-A, inheritances and gifts from abroad.
Expat returns: the foreign earned income exclusion, the foreign tax credit, treaty positions and state residency questions.
Prior-year clean-up: reconstructing filing history and preparing multi-year catch-up returns.

How I approach it

Discovery first. Before choosing a procedure I need the account statements, the entity documents and the dates — when residency started, when the account was opened, what was reported and what was not. The right path depends on those facts, and choosing the wrong one (a quiet disclosure where a streamlined submission was available, or a streamlined submission where the facts do not support non-willfulness) can cost more than the original omission.

I explain the options in plain terms, quote fixed fees for defined scopes, and prepare the filings myself. Published packages — the Streamlined Filing CPA package, FBAR filings, Form 5471 and Form 8621 preparation — are on my store; anything outside them is quoted in writing.

What I do not promise

Penalty results depend on the procedure, the facts and the IRS. Under the streamlined procedures the foreign track carries no offshore penalty for those who qualify and the domestic track carries a fixed 5% penalty; under the delinquent FBAR procedures the IRS ordinarily asserts no penalty when the income was reported. I will tell you which of those descriptions fits your facts. I will not tell you that a penalty will be zero before I have seen the records.

Who I am

Massachusetts-licensed CPA (License 26369, since 2009), with a background that includes Big 4 signatory work. Not an attorney; no legal advice. Remote practice, meetings anywhere in the U.S. by appointment. Read How It Works for how an engagement runs, or use the contact page to describe your situation.