International Taxation
Andreozzi Bluestein LLP provides representation and guidance to individuals with interests in foreign accounts and businesses.
International Taxation
Andreozzi Bluestein LLP provides representation and guidance to individuals with interests in foreign accounts and businesses.
We represent an extensive international client base of individuals and businesses in a wide range of issues including foreign bank account reporting, Subpart F and controlled foreign corporation issues, residency and domicile matters, transfer pricing issues, and foreign trust matters. This includes taxpayers who have moved abroad, and those residing in the United States with interests in foreign bank accounts, investment accounts, businesses and other assets held abroad. This also includes individuals under examination for late filing or failing to file information reports required under the Internal Revenue Code (Title 26) or the Bank Secrecy Act (Title 31), such as the Foreign Bank Account Report (FBAR). Our firm’s criminal and civil tax litigation groups are led by attorneys with decades of combined experience with Internal Revenue Service Office of Chief Counsel and the United States Department of Justice.
Foreign Business Information Reporting
FBAR (Foreign Bank Account Reporting) & FATCA (Foreign Account Tax Compliance Act)
Voluntary Disclosure Representation
Transfer Pricing
Permanent Establishment
Residency/Domicile Issues
Latest News
Voluntary Disclosure options for taxpayers after the closing of the OVDP
By: Tiffany D. Bell When the IRS closed the 2014 OVDP last fall, which had provided an avenue for taxpayers to come into compliance with any past offshore tax and information reporting, it left many taxpayers and tax ...
Read moreThink the IRS is quiet during the Shutdown? Think Again! Another Form 3520 Trap for the Unwary
By: Randall P. Andreozzi Things are emerging from the abyss that is the longest government shutdown in United States history. Yes, there exist some things so resilient, so pervasive, so constant they can survive and ...
Read morePlanning to file a Delinquent 1120F Return? Make sure you know the Risks.
By: Lou Carlow On February 1, 2018 the Commissioner of Internal Revenue, Large Business and International Division (LB&I) issued a memorandum providing guidelines for handling delinquent Forms 1120-F and requests for waivers ...
Read moreRecent Tax Court Ruling Limits Statute of Limitations for Foreign Account Reporting
By: Tiffany D. Bell, Esq. In 2010, Congress added to the anxiety of tax practitioners when it expanded the statute of limitations for the IRS to assess income taxes to six years when a taxpayer fails to include Form 8938 with his ...
Read moreIRS Offshore Voluntary Disclosure Program Will End on September 28, 2018
By: Randall P. Andreozzi, Esq. The IRS announced on Wednesday that it will officially end the 2014 Offshore Voluntary Disclosure Program (affectionately known to practitioners as the “OVDP”) on September 28, 2018. The Agency ...
Read moreFBAR Penalties – The Government’s Coin-Flip Burden of Proof on Willfulness
By: Heather L. Marello, Esq. The Bank Secrecy Act of 1970, Pub. L. 91-507, 84 Stat 114 (Oct. 26, 1970), addressed the government’s desire to monitor the use of foreign bank accounts for illegal activities by authorizing the ...
Read moreIRS Relaxes Bona Fide Residency Rules in the Wake of Hurricanes Irma and Maria
By: Heather L. Marello, Esq. In the wake of recent hurricanes that devastated Puerto Rico and the U.S. Virgin Islands, IRS released Notice 2017-56, Physical Presence of Certain Individuals in the Commonwealth of Puerto Rico or ...
Read moreIRS Delinquent 1120F Campaign – Are You Prepared?
By: Lou Carlow The IRS has identified the failure to file Forms 1120-F as the most recent front for its enhanced campaign to enforce compliance. This campaign sends a clear message to foreign businesses with a U.S. business ...
Read moreHow U.S. Foreign Information Reporting applies to Your Cross Border Holdings
By: Michael J. Tedesco As another filing season is upon us, it is important to be aware of the extensive information reporting associated with holding assets outside of the U.S. Failing to file necessary information returns or ...
Read moreAndreozzi Bluestein Attorneys Speak on Federal and State Compliance Issues
Buffalo Law Journal’s Michael Petro interviewed Andreozzi Bluestein’s Senior Associate Michael Tedesco and Associate Heather Schmidt on federal and state compliance issues for his Tax Law Special Report. Petro’s federal ...
Read moreWe are a law firm built on Experience, Vision & Trust
Whether you need tax counsel for litigation, representation before the IRS, an advocate in tax controversies, or thorough tax analysis and objective consulting, our attorneys have the experience and obtain lasting solutions.