Domestic and foreign clients regularly retain Ghatrehee Law Firm PLLC for tax-efficient structuring of their cross-border transactions and operations, as well as international tax advocacy before the Internal Revenue Service.
We assist clients in the planning and the implementation of in-bound and out-bound transactions, alert to the possibility that an audit or controversy may ensue. We represent U.S. taxpayers participating in various IRS Offshore Voluntary Disclosure Programs (OVDP), the Streamlined Foreign Compliance Procedures, Streamlined Domestic Offshore Compliance Procedures, Delinquent Filing Procedures and other forms of voluntary disclosures regarding foreign financial accounts.
We have expertise to assist in determining the proper path forward for each client, whether that path may lead to an IRS voluntary disclosure program or otherwise. Issues often present in these matters include the failure to report a beneficial or legal ownership interest in foreign financial accounts; unfiled, false or incomplete income tax returns, Foreign Bank Account Reports (FBAR) or other required information returns; unreported foreign trust, foundation or corporate structures; and estate and gift tax issues associated with undeclared offshore accounts or assets.