International Tax

Coordinating international tax treaties and returns to keep you compliant

With years of experience in international tax law, we coordinate international tax treaties and returns to U.S. tax returns. We file all U.S. tax returns for foreign assets, foreign nationals, and dual citizens.

International Tax Forms

  • FBAR (FinCEN 114) — Report of Foreign Bank and Financial Accounts
  • Form 8938 — Statement of Specified Foreign Financial Assets (FATCA)
  • Form 3520 — Annual Return to Report Transactions with Foreign Trusts
  • Form 5471 — Information Return of U.S. Persons with Respect to Certain Foreign Corporations
  • Form 8621 — Information Return by a Shareholder of a Passive Foreign Investment Company (PFIC)

Countries We Have Worked With

UK, France, Germany, Italy, Iran, Syria, Saudi Arabia, Colombia, Peru, Mexico, Australia, Israel, India, Cayman Islands, and more.

Foreign Banks We Have Worked With

BCN Switzerland, Cayman National Bank, Appleby, Bank Leumi Israel, Citibank Colombia, Skandia, Handelsbanken Sweden, UBS Switzerland, Bank of India, HypoVereinsbank Germany, Dresdner Bank, and more.

International Tax Services

  • Dual citizen compliance
  • FATCA reporting and compliance
  • International estate planning
  • IRS litigation for nonresidents
  • Voluntary disclosures
  • Entity classification and check-the-box planning
  • Tax minimization strategies
  • Foreign tax credits
  • Subpart F and PFIC analysis
  • Cross-border transactions
  • International mergers and acquisitions
  • Joint ventures
  • International e-commerce
  • Dual consolidated loss
  • Transfer pricing

Offshore Voluntary Disclosure Program & Streamlined Domestic Offshore

If you have unreported foreign accounts or assets, we can help you come into compliance. The Streamlined Domestic Offshore Procedures carry a 5% penalty on the highest aggregate balance, compared to 27.5% under the traditional Offshore Voluntary Disclosure Program (OVDP).

We have extensive experience with FBAR reporting requirements and voluntary disclosures from around the world.

FBAR Penalties

The penalty for failing to file an FBAR can be up to 50% of the account balance per year. The willfulness standard is a preponderance of the evidence — meaning the IRS only needs to show it is more likely than not that you knew about the filing requirement.

Do not wait to come into compliance. Call (303) 626-7000 or email Phil@ColoradoLegal.com to discuss your international tax situation.

Ready to Get Started?

Contact Philip Falco, Attorney & CPA, for expert tax representation in Denver.