International Tax and Transactions Attorneys in Boulder, Colorado

Our comprehensive understanding of the rapidly changing laws and policies that affect people with substantial foreign assets allows us to effectively guide taxpayers through the Internal Revenue Service’s voluntary disclosure procedures, streamlined filing compliance procedures, or delinquent international information return submission procedures. The IRS voluntary disclosure procedures are designed to provide taxpayers who have unfiled reports or returns and are concerned that their conduct is willful or fraudulent and/or may rise to the level of tax and tax-related criminal acts with an opportunity to come into compliance with the law and potentially avoid criminal prosecution. A timely voluntary disclosure may also mitigate exposure to civil penalties. While participation in the voluntary disclosure procedures is not recommended in every situation, it can be a useful tool for minimizing the risk inherent in disclosing previously undisclosed foreign financial account information and filing required returns.

The Streamlined Filing Compliance Procedures and delinquent international information return submission procedures are designed to allow taxpayers to correct past mistakes when those taxpayers have unfiled reports or returns and did not commit any tax or tax related crimes and therefore do not need the voluntary disclosure practice to seek protection from potential criminal prosecution.

We can also assist taxpayers in preparing and filing delinquent (or current) Report of Foreign Bank and Financial Account (FBAR) forms using the IRS’s delinquent FBAR submission procedures. A U.S. citizen or resident that has a financial interest in or signature authority over foreign financial accounts must file an FBAR if the aggregate value of all foreign financial accounts exceeds $10,000 at any time during the calendar year.

As the global economy expands, more Colorado-based businesses find themselves doing business overseas. The options are numerous: outsourcing, manufacturing, distribution, technology transfers, joint ventures, and so forth. We continually stay abreast of global legal and tax developments that affect our clients and their businesses. We have advised clients and structured transactions involving:

• Australia

• Bangladesh

• Bhutan

• Bolivia

• Brazil

• Bulgaria

• Canada

• China

• Costa Rica

• Croatia

• Cayman Islands

• Egypt

• England

• France

• Ghana

• Greece

• Honduras

• Hong Kong

• India

• Iraq

• Ireland

• Israel

• Ivory Coast

• Japan

• Lithuania

• Macao

• Mexico

• Mongolia

• Netherlands

• Panama

• Peru

• Philippines

• Russia

• Saudi Arabia

• Seychelles

• Singapore

• South Africa

• South Korea

• Spain

• Turkey

• Venezuela

The firm’s principal, Howard O. Bernstein, authors the International Business Transactions chapter of the Colorado Bar Association’s Practitioner’s Guide to Colorado Business Organizations and moderated the International Commercial Transactions Continuing Legal Education Program for the Colorado Bar Association.