Abogados de International Taxes

International Tax Lawyers Across the United States

Americans with income, assets, or business operations abroad face a separate layer of tax obligations that domestic-only filers never encounter. International tax lawyers help individuals and businesses meet U.S. reporting requirements while minimizing exposure to double taxation and penalties. The IRS has sharply increased enforcement in this area — collecting over $12 billion in offshore compliance efforts since 2009.

What International Tax Law Covers

This practice area deals with the tax rules that apply when money, assets, or business activity crosses national borders. Lawyers in this field handle FBAR filings, FATCA compliance, transfer pricing disputes, foreign tax credit calculations, and treaty-based tax planning.

They also advise on the tax treatment of controlled foreign corporations, passive foreign investment companies, and expatriation tax issues. If you hold foreign bank accounts with a combined value exceeding $10,000 at any point during the year, you have a filing obligation most people don't know about until it's too late.

When to Hire an International Tax Lawyer

• You received an IRS notice related to unreported foreign accounts or offshore income
• You own a business with operations, subsidiaries, or suppliers in other countries
• You're a U.S. citizen living abroad and need help with foreign earned income exclusions or tax treaty benefits
• You want to participate in the IRS Streamlined Filing Compliance Procedures to correct past non-filings
• You're renouncing U.S. citizenship and need to understand the exit tax

How the Process Works

An international tax lawyer starts by reviewing your full financial picture — domestic and foreign accounts, investments, entities, and income sources. They identify which forms you need to file and whether any past filings were missed or incorrect.

If penalties are already in play, the lawyer may pursue relief through IRS voluntary disclosure programs or penalty abatement requests. For businesses, the process often includes structuring operations to take advantage of tax treaties between the U.S. and other countries. Most compliance matters resolve within 6 to 18 months depending on complexity.

How Penalties and Tax Outcomes Are Determined

• FBAR penalties for non-willful violations can reach $10,000 per account per year; willful violations can exceed $100,000 or 50% of account balances
• Foreign tax credits offset taxes already paid to another country, reducing your total U.S. liability dollar for dollar
• The foreign earned income exclusion allows qualifying taxpayers to exclude over $120,000 of foreign earnings from U.S. taxation
• Transfer pricing adjustments can shift millions in taxable income between jurisdictions, directly affecting a company's bottom line
• Streamlined filing participants with non-willful conduct may face a 5% miscellaneous offshore penalty instead of much steeper standard penalties

Frequently Asked Questions

Do I still owe U.S. taxes if I live and work in another country?

Yes. The United States taxes its citizens and permanent residents on worldwide income regardless of where they live. You may qualify for credits or exclusions that reduce what you owe, but the filing obligation remains. The U.S. is one of only two countries that taxes based on citizenship rather than residency.

What happens if I haven't filed FBARs for several years?

The IRS offers voluntary disclosure and streamlined compliance programs designed for people who fell behind on foreign account reporting. If you can show the failure wasn't deliberate, penalties are significantly reduced. Waiting for the IRS to contact you first removes most of those options and dramatically increases your financial exposure.