International Tax
Experienced New York International Tax Attorney for FATCA, FBAR and Other Matters
If you live in New York and earn income or have assets abroad, you need to be extremely careful to ensure that you properly report your offshore income and assets to the federal government. Multiple federal laws impose international reporting requirements, and failure to comply with these laws can lead to civil or criminal penalties. At Thorn Law Group, we have extensive experience representing clients in cross border tax matters, and a New York international tax attorney at our firm can help you avoid unnecessary liability. Individuals who also have domestic IRS questions sometimes review additional context about our work before they call.
Our International Tax Services
Along with helping taxpayers in New York meet their obligations to the federal government, we also represent taxpayers who are facing audits and investigations. As a result, our lawyers can assist if you have questions or concerns about any of the following:
Foreign Account Tax Compliance Act (FATCA) Compliance
The federal Foreign Account Tax Compliance Act requires U.S. taxpayers to report qualifying foreign financial assets to the Internal Revenue Service. Taxpayers with qualifying assets must file reports annually using IRS Form 8938. Foreign financial institutions also report these assets to the IRS, so even if you do not disclose your foreign holdings, the IRS may still know they exist.
Bank Secrecy Act (BSA) Compliance
In addition to complying with FATCA, U.S. taxpayers with foreign holdings must comply with the federal Bank Secrecy Act. This law applies specifically to offshore accounts and requires taxpayers with qualifying accounts to file an annual FBAR report.
Delinquent FBARs
If you are behind on your FBAR or IRS Form 8938 filing obligations, you will want to address this delinquency promptly before it triggers an audit or investigation if possible. If your delinquency is inadvertent, filing late may be your best option, although you will want to consult with an experienced New York international tax attorney first. You can also review helpful analysis related to current IRS enforcement trends.
Voluntary Disclosures and Streamlined Filings
If filing late is not a viable solution, you may need to submit a voluntary disclosure or streamlined filing. Both options involve risk, so careful consideration is essential. Some taxpayers examine available options to understand these processes before moving forward.
Foreign Tax Treaties
The United States maintains tax treaties with numerous countries. These treaties determine how income is taxed, help avoid double taxation and set rules for information sharing between tax authorities. Understanding the treaty provisions that apply to your country of residence or business activity is essential, because they may reduce tax exposure or create additional reporting obligations. Treaties also influence withholding rules and can affect residency status under international tax law.
Transfer Pricing for Multinational Businesses
Multinational taxpayers must comply with transfer pricing rules when they transact with related foreign entities. These rules require documentation that supports arm’s length pricing and detailed analysis of intercompany transactions. Transfer pricing issues often arise during international tax audits and can result in significant adjustments if the IRS determines that pricing does not reflect market standards. Businesses that operate abroad benefit from reviewing intercompany matters that may influence their compliance requirements.
International Tax Audits, Investigations and Litigation
Our attorneys have significant experience representing individuals and entities in cross border tax audits, investigations and litigation. If you are facing an audit, if you received a target letter or subpoena from IRS Criminal Tax Investigation, or if you need to challenge an IRS determination regarding your international tax liability, we encourage you to contact us right away.
Common Issues in IRS International Tax Cases
International tax audits, investigations, and litigation can involve a wide range of issues. We represent U.S. and foreign taxpayers in all cross-border tax matters involving the IRS, and each New York international tax attorney at Thorn Law Group has extensive experience helping taxpayers avoid unnecessary tax liability and penalties.
Some examples of common issues in IRS international tax cases that we handle for our clients include:
International Business Tax Compliance
Companies that conduct business in the U.S. and abroad are subject to a complex web of tax reporting and payment obligations. We represent companies that are facing scrutiny from the IRS related to international business tax compliance, including subpart F compliance for controlled foreign companies, foreign-derived intangible income (FDII) (known as foreign-derived deduction-eligible income (FDDEI) beginning in 2026) compliance, and other cross-border compliance matters.
Offshore Account and International Investment Tax Compliance
We assist individual and corporate U.S. taxpayers with all aspects of offshore accounts and international investment tax compliance. U.S. taxpayers can have offshore account disclosure obligations under the Foreign Account Tax Compliance Act (FATCA) and Bank Secrecy Act (BSA), and they must accurately report and pay their U.S. tax liability on international investment income as well. Noncompliance with these requirements can trigger either civil or criminal penalties depending on the circumstances involved.
Cryptocurrency Tax Compliance
International cryptocurrency tax compliance violations can trigger civil or criminal penalties as well. U.S. taxpayers who invest in cryptocurrency overseas must ensure that they consistently meet their reporting and payment obligations to the IRS. This includes the reporting and payment of quarterly estimated taxes. The IRS has enhanced its focus on cryptocurrency compliance in recent years, and it uses subpoenas and other investigative tools to obtain taxpayers’ identities and transaction histories from exchanges and other intermediaries.
Transfer Pricing Issues
Transfer pricing issues can expose U.S. taxpayers to significant liability in international IRS tax audits and investigations. Companies that conduct internal transfers between affiliates and other intercompany transactions must ensure that they price these transactions in compliance with Section 482 of the Internal Revenue Code. Transfer pricing compliance has become an enforcement priority for the IRS in recent years as well, and the IRS has devoted particular attention to transfer pricing in cross-border transactions.
U.S. Taxpayer Liability Under International Tax Treaties
Under U.S. tax treaties with foreign countries, taxpayers who are subject to overlapping income tax obligations are often eligible to pay U.S. income taxes at reduced rates. They are also eligible for U.S. income tax exemptions in some cases. However, interpreting U.S. taxpayers’ obligations under these treaties can be complicated, and mistakes and oversights are not uncommon. If you or your company is facing scrutiny from the IRS related to its liability under an international tax treaty, a New York international tax attorney at our firm can help.
Competent Authority and Mutual Agreement Procedure Cases
Our international tax attorneys can also help with competent authority matters, including the use of the Mutual Agreement Procedure (MAP) for resolving cross-border tax treaty issues. As business is increasingly becoming international, competent authority and MAP cases are becoming increasingly common as well. We are available to assist with competent authority matters involving all U.S. tax treaty partners—including countries throughout the Americas, Africa, Asia and Europe.
Foreign Taxpayer Liability to the IRS
In addition to representing U.S. citizens and businesses in international tax matters, we also represent foreign individual and corporate taxpayers that are facing IRS scrutiny. If the IRS is reassessing (or seeking to impose) U.S. tax liability based on your business activities or residence in New York or anywhere else in the United States, we can accurately determine your tax liability and then work with the IRS on your behalf. This has become a priority enforcement area for the IRS as well, and our international tax attorneys have the experience required to effectively represent foreign taxpayers who are facing significant liability in international tax audits and investigations.
Proactively Resolving Potential International Tax Issues with the IRS
Along with helping clients resolve high-stakes international tax controversies with the IRS, we also help our clients take proactive measures to avoid these controversies when possible. This includes everything from negotiating Advance Pricing Agreements (APAs) with the IRS involving potential transfer pricing-related issues to submitting streamlined filings and voluntary disclosures. If you are interested in learning what you can do to avoid the risk of facing an IRS international tax audit or investigation, we encourage you to schedule a confidential consultation with a New York international tax attorney at Thorn Law Group.
New Developments in International Tax Law for 2025 and Beyond
International tax enforcement continues to evolve. In 2025, the IRS expanded its focus on foreign asset reporting, high net worth audits, cryptocurrency disclosures involving offshore platforms and enhanced information sharing under global transparency initiatives. Increased funding also allows the IRS to conduct deeper reviews of cross border income, residency claims and treaty misuse. Taxpayers with foreign income or offshore interests should expect elevated scrutiny moving forward.
Speak with a New York International Tax Attorney in Confidence
To speak with a New York international tax attorney at Thorn Law Group in strict confidence, call us at (914) 534-6004 or contact us confidentially online. We will arrange your initial consultation as soon as possible.
