International Tax & FBAR
Strategic legal defense for offshore reporting, voluntary disclosure, and international tax enforcement.
Goldberg Tax frequently helps taxpayers come into compliance with their foreign reporting obligations, including navigating IRS and Treasury voluntary disclosure processes. With aggressive global enforcement, automatic financial data sharing, and enhanced offshore penalties, international tax compliance has become a top enforcement priority for the U.S. government.
Whether you failed to report foreign accounts, offshore income, ownership in foreign entities, or digital assets held abroad, we provide strategic legal guidance to correct past noncompliance, minimize penalties, and protect against criminal exposure.
International tax cases often escalate into formal tax litigation and aggressive tax collection & relief matters when significant penalties are assessed.
What is international tax & FBAR compliance?
U.S. taxpayers are required to disclose worldwide income and foreign financial interests. Two of the most important reporting regimes include FBAR (Foreign Bank Account Report – FinCEN Form 114) and FATCA (Foreign Account Tax Compliance Act – Form 8938). Failure to properly report foreign accounts, income, trusts, corporations, or cryptocurrency can trigger:
- Massive civil penalties
- Criminal prosecution
- Asset seizures
- Long-term IRS monitoring
These cases require specialized legal defense due to the overlap between tax law, banking law, and international reporting regulations.
International tax & FBAR matters we handle
Our approach to international tax & FBAR defense
We evaluate account balances, transaction history, residency issues, and intent (willful vs non-willful) to determine proper disclosure strategy.
We guide clients through the proper voluntary disclosure or streamlined filing paths to reduce civil penalties and protect against criminal prosecution.
We handle all communications with the IRS and Treasury, defend against FBAR penalty assertions, and challenge improper willfulness findings.
If necessary, we represent clients in tax litigation involving offshore enforcement and penalty challenges.
Why work with Goldberg Tax?
- Extensive experience with offshore tax enforcement
- Advanced FBAR & FATCA compliance strategies
- Voluntary disclosure representation
- Strong protection against criminal exposure
- Litigation-ready representation in federal courts
- Clear guidance in complex international matters
When you should hire an international tax & FBAR attorney
You should seek legal counsel immediately if:
- You failed to file FBAR (FinCEN 114)
- You failed to file Form 8938 (FATCA)
- You earned foreign income that was not reported
- You hold crypto on foreign exchanges
- You own foreign businesses or trusts
- You received an offshore audit notice
- You are concerned about criminal exposure
Once the IRS initiates contact, voluntary disclosure options may be limited or eliminated.
Frequently asked questions
Yes. Offshore enforcement remains a top IRS and DOJ priority.
Yes. Willful violations can result in penalties equal to 50% of the account balance per year.
Yes—but only if the IRS has not already initiated an investigation.
Non-willful cases may qualify for reduced penalties or streamlined programs.
Yes. Foreign crypto exchanges fall under international reporting rules.
Tell us what you're dealing with.
Confidential. No obligation. We respond within one business day.