Washington DC Offshore Tax Compliance Attorney

The dedicated offshore tax attorney at Tax Relief Counsel is here to guide you through every step of your journey toward financial peace of mind. With reliable legal assistance, you can protect your assets — and your future.

Your Trusted International Tax Compliance Lawyer in Washington, D.C.

Holding assets in foreign accounts comes with specific tax reporting obligations that many Americans may not be aware of. At Tax Relief Counsel, we understand these regulations and have helped numerous individuals and businesses come into compliance with the IRS.

Common issues we help clients resolve include:

Unreported foreign income
Foreign Account Tax Compliance Act (FATCA) filing errors
Undeclared foreign trusts
International business ownership disputes

The IRS’s offshore programs have only grown more sophisticated. A renewed focus on international tax enforcement highlights the importance of seeking legal counsel if you have unreported foreign assets.

Our founder, Ramy Shabana, is an international tax attorney with a deep understanding of offshore disclosure requirements. Whether you’re facing an IRS inquiry or proactively seeking to correct past non-compliance, we are here to provide clear, effective solutions and help you achieve peace of mind.

If you have questions or concerns about your international tax obligations, don’t hesitate to contact us for a free, confidential consultation. We’ll sit down with you, review your situation, and make a plan for moving forward.

Understanding Your Reporting Obligations

The U.S. government mandates that citizens and permanent residents, even those living and working abroad, report their income and foreign financial accounts. Here are some key obligations to be aware of.

FBAR Reporting

If the total combined balance of your foreign accounts exceeds $10,000 at any point during the year, you must file a Report of Foreign Bank and Financial Accounts (FBAR). This report is filed separately with the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN).

FATCA Compliance

The Foreign Account Tax Compliance Act (FATCA) requires you to file Form 8938 to disclose specific foreign assets if you meet certain thresholds. This form is filed with your annual tax return.

The High Stakes of Non-Disclosure: Potential Consequences You Can't Afford to Ignore

Failing to meet your reporting obligations for foreign accounts and assets can have severe repercussions.

Hefty Civil Penalties

The IRS can impose significant fines for each year of non-compliance, often calculated per form. Penalties can easily reach tens of thousands of dollars, with common violations including failure to file FBARs, Form 8938, and similar forms.

Accrued Interest Charges

On top of penalties, you will be charged interest on any unpaid taxes related to your undisclosed assets. This interest can accumulate quickly and substantially increase your total tax liability.

Criminal Prosecution

In cases of deliberate tax evasion, fraud, or efforts to conceal assets, you could face criminal charges. A conviction can result in substantial fines, imprisonment, and lasting damage to your reputation.

IRS Audits and Scrutiny

Failing to disclose foreign accounts significantly increases your chances of being audited by the IRS. Audits can be stressful, time-consuming, and financially burdensome.

Asset Seizure

The IRS has broad authority to seize assets to satisfy unpaid tax debts, including levying bank accounts, garnishing wages, and placing liens on property.

Common Options for Disclosing Offshore Accounts

The IRS provides multiple voluntary disclosure options to allow non-filers to accurately report their global income and file their international information returns. These options come with varying levels of protection, filing requirements, and penalties.

Streamlined Domestic Offshore Procedures (SDOP)

These procedures are for taxpayers who non-willfully failed to declare their foreign income and file FBARs.

These individuals must submit a thorough explanation of their behavior, amend their tax returns for three years, and file FBARs for six years. They must also pay the owed taxes, along with interest, penalties, and a 5% offshore penalty based on the highest value of their foreign accounts.

Streamlined Foreign Offshore Procedures (SFOP)

The SFOP provisions are similar to the domestic procedures, with a few key differences. They apply to individuals who don’t reside in the United States, and there’s no additional penalty for keeping their offshore assets.

Voluntary Disclosure Program (VDP)

The IRS’s Voluntary Disclosure Program allows taxpayers to come forward voluntarily and disclose their previously undisclosed offshore assets and income. It’s available to both willful and non-willful taxpayers.

Participants in the VDP are typically required to file amended tax returns and FBARs for multiple years and pay back taxes, interest, and certain penalties. The penalties under the VDP can vary based on the taxpayer’s specific circumstances.

Delinquent FBAR Submission Procedures

These procedures allow taxpayers who have failed to report and pay taxes on foreign income in a timely fashion to offer a statement explaining why they’re filing their FBARs late. There are no penalties for these procedures.

Quiet Disclosure

Quiet disclosure involves filing amended tax returns and international information returns outside the parameters of the IRS’s disclosure options. If tax authorities discover this, they could impose higher civil penalties than those for other disclosure options, making this a risky approach.

The following helpful table is designed to give you a better understanding of the IRS’s various disclosure options:

Disclosure Program	Eligibility Criteria	Non-Willful or Willful	Number of Years to Amend	FBAR Filing Requirement	Penalty Structure
Streamlined Domestic Offshore Procedure (SDOP)	U.S. taxpayers, including certain non-residents	Non-Willful	3 years of tax returns	6 years of FBARs	Penalty based on undisclosed assets' highest balance
Streamlined Foreign Offshore Procedure (SFOP)	U.S. taxpayers residing abroad	Non-Willful	3 years of tax returns	6 years of FBARs	Penalty based on undisclosed assets' highest balance
Voluntary Disclosure Program (VDP)	Typically for willful non-compliance	Willful	Varies by case	Varies by case	May include substantial civil penalties, depending on individual circumstances
Delinquent FBAR Submission Procedures	Taxpayers who only failed to file FBARs	Not applicable	None (FBARs for the past 6 years)	6 years of FBARs	Generally no specific penalties for late FBAR submissions
Quiet Disclosure	Any taxpayer who amends prior tax returns and FBARs without entering a formal program	May vary	Varies by case	Varies by case	Risks penalties if tax authorities discover the disclosure

If you’re uncertain which offshore disclosure program is best for your specific situation, Ramy Shabana, our international tax lawyer in Washington, D.C., can help.

Protect Your Assets and Your Future — Get a Free Case Review

If you’re concerned about your non-disclosure, take the first step toward protecting your financial future by scheduling a no-cost case review with our offshore disclosure lawyer.

Call Me Personally

(202) 630-4095

Our Approach to International Tax Compliance

At Tax Relief Counsel, we understand how daunting offshore disclosure can be. When you have questions, we provide personalized guidance and support every step of the way:

Thorough Assessment:
We review your foreign assets, income sources, filing history, and any previous disclosures in order to tailor a strategy that meets your unique needs.
Clarification and Guidance:
We clearly explain your options — such as the SDOP, the VDP, and delinquent FBAR submission procedures — and guide you on how to move forward.
Preparation and Filing:
We handle all necessary paperwork, completing your tax forms, FBAR filings, and other required documents accurately and on time.
Proactive Penalty Mitigation:
When you face potential penalties, we leverage our knowledge of IRS procedures and negotiation skills to advocate for you.

It’s never too early or too late to reach out for assistance. Contact us for personalized guidance on international tax compliance.

Why Choose
Tax Relief Counsel?

To the legal professionals at Tax Relief Counsel, you’re more than just a case number — you’re an individual and a partner in achieving tax compliance. You’ll enjoy the following benefits when you work with us.

Flat Fee Structure

We offer a predictable flat fee structure, ensuring that our clients know exactly what to expect without any hidden costs or surprises.

Worldwide Reach

With our remote services, our tax relief attorney can assist clients with offshore tax compliance regardless of their location, providing dynamic, customized solutions for a global clientele.

Experience in Offshore Disclosure

We have a proven track record in handling offshore disclosure cases. Our experience allows us to offer each of our clients tailored guidance and support while they navigate complex international tax regulations.

Transparent Communication

We prioritize open and transparent communication with our clients. Attorney Ramy Shabana will correspond with you personally about your tax matters and legal strategy.

Testimonials

FAQs

What is a reasonable cause in regard to disclosures?

Reasonable cause is a type of explanation a taxpayer gives to justify their non-compliance. It applies in situations where the taxpayer has made a mistake in good faith by doing something incorrectly or not following the correct procedures.

To offer a reasonable cause, the taxpayer cannot be under investigation by the IRS for civil or criminal reasons. The IRS will thoroughly check all information and contributing circumstances to ensure that the taxpayer acted reasonably. Section 20.1.1.3.2.1 of the Internal Revenue Manual covers the agency’s reasonable cause standards.

Reasonable cause is available to taxpayers who have tried their best to fulfill their tax obligations with care and prudence but still failed to comply. Although this option can potentially exempt them from penalties, it isn’t a guarantee — the IRS may still impose penalties if it finds that reasonable cause doesn’t exist.

The agency will thoroughly assess the situation, the reasons behind it, and the obstacles the taxpayer faced in complying. If their circumstances have changed, they must take appropriate action to rectify the errors. If they were aware of non-compliance but failed to act, they cannot claim reasonable cause.

Our experienced offshore disclosure attorney can help you navigate this process.

What is voluntary disclosure?

Taxpayers who have made errors in their past tax filings can correct them through voluntary disclosure.

The IRS considers voluntary disclosures when deciding whether to recommend criminal prosecution. However, making a voluntary disclosure for offshore accounts doesn’t automatically provide immunity from prosecution. Nonetheless, it could be a factor in the decision not to recommend prosecution.

To make a voluntary disclosure to IRS Criminal Investigation, you must provide complete, truthful, and timely information. Additionally, as the taxpayer, you have an ongoing responsibility to work with the agency to address any tax liabilities, and you must make good faith efforts to pay any required taxes, interest, and penalties.

Who processes offshore disclosures?

If you submit your disclosure through the streamlined program, whether domestic or foreign, it will be processed at the IRS’s Austin, Texas, office. However, if you have a more serious or pressing disclosure, it will go through pre-clearance in Philadelphia before being sent to Austin for processing and finally undergoing examination at a field office near you.

Delinquent FBARs can be filed online through the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) website.

Request a No-Obligation Consultation Today

Compliance is within your reach. Schedule a free, confidential case review with Ramy Shabana, our offshore disclosure lawyer, to safeguard your financial future.