Expatriation of Individuals IRS Compliance Campaign

Expatriation of Individuals IRS Compliance Cam

Expatriation of Individuals & the IRS

Expatriation of Individuals: In recent years, the Internal Revenue Service has made offshore reporting and international tax compliance a key enforcement priority. Penalties for being out of foreign accounts compliance can be steep. And, while expatriation is not as common as FBAR or FATCA reporting (both of which are key enforcement initiatives), the IRS is beginning to make good on its promise for 2019 in accordance with the Expatriation Compliance Campaign. 

New International Tax Compliance Campaigns

In June of 2019, the IRS announced 6 new enforcement campaigns, and one of then was expatriation.

Since then, the number of individuals seeking assistance with these types of matters has significantly increased.

To date, LB&I has announced a total of 59 campaigns.

The campaigns described below were identified through LB&I data analysis and suggestions from IRS employees. LB&I’s goal is to improve return selection, identify issues representing a risk of non-compliance, and make the greatest use of limited resources.

The new campaigns are:

  • Expatriation
    • Practice Area: Withholding & International Individual Compliance

Expatriation Enforcement Campaign

As provided by the IRS:

Practice Area: Withholding & International Individual Compliance

 Lead Executive: John Cardone, director of Withholding & International Individual Compliance

Campaign Point of Contact: Ursula Gee

U.S. citizens and long-term residents (lawful permanent residents in eight out of the last 15 taxable years) who expatriated on or after June 17, 2008, may not have met their filing requirements or tax obligations. The Internal Revenue Service will address noncompliance through a variety of treatment streams, including outreach, soft letters, and examination.”

Interested in Expatriation from the U.S.?

Our firm specializes exclusively in international tax.

We are the “go-to” firm for other Attorneys, CPAs, Enrolled Agents, Accountants, and Financial Professionals across the globe. Our attorneys have worked with thousands of clients on offshore disclosure matters, including FATCA & FBAR.

Each case is led by a Board-Certified Tax Law Specialist with 20-years experience, and the entire matter (tax and legal) is handled by our team, in-house.

*Please beware of copycat tax and law firms misleading the public about their credentials and experience.

Less than 1% of Tax Attorneys Nationwide Are Certified Specialists

Our lead attorney is one of less than 350 Attorneys (out of more than 200,000 practicing California Attorneys) to earn the Certified Tax Law Specialist credential. The credential is awarded to less than 1% of Attorneys.

Recent Case Highlights

  • We represented a client in an 8-figure disclosure that spanned 7 countries.
  • We represented a high-net-worth client to facilitate a complex expatriation with offshore disclosure.
  • We represented an overseas family with bringing multiple businesses & personal investments into U.S. tax and offshore compliance.
  • We took over a case from a small firm that unsuccessfully submitted multiple clients to IRS Offshore Disclosure.
  • We successfully completed several recent disclosures for clients with assets ranging from $50,000 – $7,000,000+.

How to Hire Experienced Offshore Counsel?

Generally, experienced attorneys in this field will have the following credentials/experience:

  • 20-years experience as a practicing attorney
  • Extensive litigation, high-stakes audit and trial experience
  • Board Certified Tax Law Specialist credential
  • Master’s of Tax Law (LL.M.)
  • Dually Licensed as an EA (Enrolled Agent) or CPA

Interested in Learning More about our Firm?

No matter where in the world you reside, our international tax team can get you IRS offshore compliant.

We specialize in FBAR and FATCA. Contact our firm today for assistance with getting compliant.

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