The IRS imposes significant penalties for failures related to international information reporting. Typical reporting requirements relate to U.S. taxpayers with foreign assets, accounts, businesses, trusts, or gifts. Penalties are often assessed on a per form, per year basis, and can apply even when no tax is owed. An experienced international tax defense attorney can help challenge and avoid these information return penalties.
Common Reporting Forms & Returns
Some key international information reporting forms include:
- Form 926
- Form 3520
- Form 5471
- Form 5472
- Form 8858
- Form 8865
- Form 8938
- FBAR (FinCEN Form 114)
Penalty Defense Process & Strategy
- Consider engaging an experienced international tax controversy attorney as soon as possible.
- Consider Streamlined Filing Compliance or Voluntary Disclosure (if eligible)
- Don’t ignore IRS correspondence, be proactive, meet deadlines or obtain extensions.
- Carefully evaluate eligibility to assess risk and develop a penalty abatement strategy.
- Prepare supporting documentation and respond to IRS requests.
- Reasonable Cause / Penalty Abatement Request
Contact an experienced international tax controversy lawyer
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