Cross-border individuals and families often face U.S. reporting rules that are easy to miss and expensive to fix. We help clients plan ahead, come into compliance, and respond to the IRS.
Scope of representation
- IRS notices, examinations and collection matters
- FBAR (FinCEN Form 114) and foreign-asset reporting, including late filings
- Foreign trusts, foreign gifts and inheritances (Forms 3520 / 3520-A) and foreign corporations (Form 5471)
- Pre-immigration tax planning before a green card or U.S. residency
- Real-estate transactions, including 1031 and reverse 1031 exchanges
- Representation before the U.S. Tax Court
How a matter proceeds
- Read the notice or define the question. Tax years, forms, amounts and dates.
- Gather the record. Returns, account statements and entity documents.
- Resolve or plan. Respond, file, or implement a plan, with a written scope and fee.
Timing and fees
Timing depends on the notice, the agency or court, and the facts. Response dates stated in a notice are reviewed individually as soon as we receive it. Scope, fees and any deposit are discussed before we are engaged and confirmed in a written engagement letter.
Facing a deadline? Call (520) 358-5095. An online appointment request does not extend any government or court deadline.
Documents for an initial review
- Any IRS notice (all pages)
- Recent tax returns
- A list of foreign accounts, entities and trusts (no account numbers needed at this stage)
E-mail copies to info@attorneywu.com with the subject “Your name – short description”. Please do not send documents through the chat or the booking form.
Frequently asked questions: tax controversy, international reporting and pre-immigration planning
Who must file an FBAR, and when is it due?
A U.S. person (including green-card holders and tax residents) whose foreign financial accounts total more than US$10,000 at any time during the year must file FinCEN Form 114 (FBAR). It is due April 15, with an automatic extension to October 15. Penalties for non-willful and willful failures differ greatly, so late filers should get advice before filing.
Why plan taxes before moving to the U.S. or getting a green card?
Once you become a U.S. tax resident, the U.S. generally taxes your worldwide income and requires reporting of foreign accounts, companies and trusts. Steps taken before residency — such as reviewing the basis of appreciated assets, timing income, restructuring foreign companies, and making gifts or trusts — can be far more effective than fixes afterward.
I received an IRS Notice of Deficiency. What is the deadline?
A Notice of Deficiency (the “90-day letter”) generally gives 90 days from its date to petition the U.S. Tax Court — 150 days if it is addressed to a person outside the United States. Filing on time lets you dispute the tax before paying it. The deadline is strict, so contact counsel as soon as the letter arrives.
General information only, not legal advice. Book a consultation for advice on your situation.
Insights on this topic
- U.S. Assets, Non-U.S. Families: Begin With Status and Ownership
- When CBP Holds Your Shipment: What to Gather First
- Estate Planning for Nonresident Aliens Who Own U.S. Real Estate: Federal Tax Issues
- Understanding Reverse 1031 Exchanges and the Risks of International Fund Transfers
- NRA Grantor Trusts with U.S. Beneficiaries: Comparing Domestic and Foreign Structures
- Understanding the Grantor Trust Rules Under IRC § 679: Key Considerations for Foreign Trusts
