Washington DC International Tax Attorneys

Sophisticated Counsel

United States-based companies transacting business overseas face many challenges in terms of tax compliance. These entities are subject to the local taxing authorities in the host jurisdiction and must still comply with U.S. tax laws. While certain countries have entered into tax treaties with the United States that enable businesses to avoid the pitfall of “double taxation,” others have not. As the global marketplace continues to expand, double taxation has the potential to become even more problematic for U.S. businesses. Additionally, increased collaboration inspired by FATCA between the United States and foreign governments has led to stepped up enforcement efforts in such areas as anti-money laundering, Foreign Corrupt Practices Act (FCPA), and foreign bank account reporting.

The Internal Revenue Service has also renewed its efforts to pursue tax law violations arising out of foreign activities and offshore bank accounts. It is aggressively pursuing international tax violations through the use of both civil audits and criminal investigations and prosecutions. The IRS has announced specific plans to focus on combating tax fraud and tax evasion by auditing U.S. taxpayers who use foreign accounts and offshore business entities in ways the IRS deems abusive or misleading. To assist in these efforts, the IRS and the Department of Justice (DOJ) have expanded their programs of information sharing and cooperation with nations, banks and financial institutions around the world.

The experienced lawyers at Thorn Law Group advise companies, banks, trusts and other organizations grappling with international tax law issues. Our attorneys provide sophisticated international tax planning and tax dispute resolution services. Each Washington DC international tax attorney at our firm has the skills necessary to handle all types of tax matters, ranging from resolving complex disputes with international banks to counseling clients facing a government investigation of an offshore business or bank account. Our skilled tax lawyers in Washington, DC focus on developing strategies and tactics aimed at managing our clients’ exposure while bringing their disputes to a quick and amicable resolution.

Offshore Bank Account and Foreign Financial Asset Disclosures: 2025 Update

For many U.S. taxpayers, complying with the offshore bank account and foreign financial asset disclosure requirements under the Bank Secrecy Act (BSA) and FATCA is a necessity. The BSA and FATCA both impose disclosure requirements for U.S. taxpayers, and they both allow for civil and criminal enforcement in the event of noncompliance.

While the BSA and FATCA are similar in that they both impose disclosure requirements for certain foreign financial assets, their specific requirements are very different. For example, they apply to different types of foreign financial assets, they have different reporting thresholds, and they have different filing due dates. As of 2025, the basic requirements under the BSA and FATCA are:

• Foreign Financial Assets Subject to Disclosure – The BSA applies to offshore bank accounts, while FATCA applies to offshore bank accounts, foreign stocks and securities, foreign financial instruments, and other “specified” foreign financial assets.
  
  
• Reporting Thresholds – U.S. taxpayers must comply with the BSA if the aggregate value of their offshore bank accounts exceeds $10,000 at any time during the calendar year. Taxpayers living in the U.S. must comply with FATCA if the total value of their specified foreign financial assets was more than $50,000 on the last day of the tax year or more than $75,000 at any time during the tax year (both figures are doubled for married taxpayers filing jointly).
  
  
• Reporting Deadlines – Under the BSA, taxpayers must file an FBAR by April 15 of each year, though all taxpayers receive an automatic extension to October 15. Under FATCA, taxpayers must file IRS Form 8938 when they file their annual income tax return.

A key question for many U.S. taxpayers is whether the reporting requirements under the BSA and FATCA apply to cryptocurrency and other digital assets held overseas. Unfortunately, this question still does not have a clear answer as of 2025, and this makes it essential for taxpayers who have concerns to consult with an experienced Washington D.C. international tax attorney. While the Financial Crimes Enforcement Network (FinCEN), which is part of the U.S. Treasury, stated that it intended to propose regulations under the BSA that would require reporting of cryptocurrency accounts in 2020, it still has yet to do so. Even so, reporting of offshore cryptocurrency holdings may still be required in certain circumstances.

Global Intangible Low-Taxed Income (GILTI) Compliance for U.S. Taxpayers that Own Foreign Companies

Another key international tax issue for many U.S. taxpayers is global intangible low-taxed income (GILTI) compliance. At Thorn Law Group, we have extensive experience with GILTI compliance (and enforcement); and if you have questions or concerns, a Washington D.C. international tax attorney at our firm can explain everything you need to know.

In short, GILTI is a federal tax that applies to U.S. companies that own more than 50 percent of a foreign corporation and individuals who own more than 10 percent of the corporation. It applies specifically to income derived from intellectual property (IP) and other intangible assets, and it is intended to deter the use of foreign corporations as tools for federal tax avoidance. As a result, the IRS (and other federal authorities) take GILTI compliance very seriously, and allegations of noncompliance can expose both individual and corporate taxpayers to substantial penalties.

Thorn Law Group – National Reputation, International Capabilities

Thorn Law Group’s attorneys specialize in representing individuals and businesses worldwide dealing with international tax issues. Our clients include:

In order to best meet the needs of our clients, we have developed an extensive network of law firms, legal practitioners and financial professionals around the globe to help counsel our clients facing complex foreign tax issues. These relationships allow our experienced legal team to advise clients on a complete range of international tax matters, including:

To learn more about how a Washington DC international tax attorney at Thorn Law Group can assist you with international tax issues, contact Kevin E. Thorn, Managing Partner of the Thorn Law Group, at (202) 349-4033.