Any U.S. taxpayer is expected to comply with IRS rules and regulations, including in situations where a U.S. affiliated person lives abroad. There are strict rules in the United States for taxpayers who have financial accounts outside of this country, even if those taxpayers are living in a foreign jurisdiction and simply have an account in a bank where they live. Depending on the account's value, requirements may include filing an annual Report of Foreign Bank and Financial Account (FBAR). Taxpayers may also be required to disclose foreign assets by filing Form 8938 with their tax returns.

Managing Partner Kevin E. Thorn was recently asked by a DC news source to comment on former Trump campaign chairman Paul Manafort’s trial taking place in a federal court in Alexandria, Virginia.

Swiss banks had a long tradition of providing privacy and providing top quality service. This prompted wealthy individuals and businesses from throughout the world to invest their funds in Swiss banks.  However, in recent years, many Swiss banks have been forced to turn over financial information and account details on foreign investors with Swiss bank accounts. 

Individuals who own offshore bank accounts or who have signature authority over offshore bank accounts have certain reporting requirements. When an individual with any kind of offshore accounts is required to file disclosure forms and fails to do so, civil and criminal penalties could be imposed as a result of this failure. The Offshore Voluntary Disclosure Program (OVDP) was designed to allow accountholders to come forward and admit to past failures to submit required disclosures while avoiding criminal penalties and limiting civil fines.

If you have any type of investments or financial products offshore, you must understand the rules for reporting those accounts and for paying taxes on investment income. A Virginia tax law firm can assist you in complying with the legal requirements for your accounts. If you have failed to comply in the past with reporting and tax requirements, an attorney can also help you to determine what options you have to minimize the possibility of penalties as the IRS becomes more aggressive at identifying offshore funds.