Foreign Bank Account Reporting (FBAR)
Taxpayers who hold overseas accounts or assets are required to disclose these assets through FBAR disclosure when the value of their account exceeds $10,000 at any time during the year. Failure to file FBAR can subject taxpayers to significant penalties, fines, and even a potential prison sentence. A willful FBAR violation, that is an intentional or voluntary disregard of the legal duty, can escalate the penalties rather quickly. Thus, it is imperative that taxpayers file their FBARs timely and diligently, more so than their federal or state tax returns. Your advisors at Carbon Law Group are ready to help you with all FBAR filings.
Passive Foreign Investment Company (PFIC) Advisory
- PFIC rules apply to Excess Distributions to US owners from their passive foreign investment companies. The rules impose an exceedingly high tax liability at ordinary income tax rates on such excess distributions.
- Determining whether a company is a PFIC is no easy feat and requires heavy analysis into the books of the entity to find out the passive vs non-passive asset and income ratios.
Here at Carbon Law Group, we can help you at all stages of PFIC advisory, from income and asset testing to filing the right forms to minimize your tax liability.
Inbound/Outbound Tax Planning
International tax planning is a complex area of law full of tax treaties and multi-jurisdictional tax rules. Carbon Law group will provide you with advice and guidance to accurately comply with these rules and take advantage of all potential advantages and planning opportunities.
Foreign Entity Information Tax Return Preparation (Forms 5471 and 8858)
Having interest in a foreign entity can potentially subject taxpayers to filing information tax returns for these entities. This will depend on whether the taxpayer falls into the categories specified by the Treasury, mandating the filing. Whether it is a disregarded entity, or a corporation, the attorneys at Carbon Law Group will make sure your foreign filings are made timely and accurately.