International Tax Attorneys for Cross-Border Compliance and Disputes

U.S. tax follows its citizens and residents wherever their money is. Foreign accounts, foreign businesses, and foreign income all carry reporting duties, and the penalties for missing them can dwarf the tax itself.

Whether you have accounts you never reported, a notice about a foreign asset, an interest in a company abroad, or plans to give up citizenship or a green card, the first job is to map the exposure. The second is to choose the path back into compliance that fits the facts, because picking the wrong one can forfeit protections you would otherwise have. Whiteford represents individuals and businesses in cross-border reporting, offshore disclosures, and international tax disputes.

Worldwide income, and the reporting that comes with it

U.S. citizens and residents owe U.S. tax on income earned anywhere in the world. The foreign earned income exclusion and foreign tax credits soften double taxation, but they do not remove the duty to report. Nonresidents are generally taxed only on U.S.-source income and income connected to a U.S. business. The rules that cause the most trouble are the reporting rules, because many taxpayers never knew they applied to them.