Annapolis International Taxation Lawyer

Recognized international taxation representation for individuals and companies with cross-border interests.

If you hold foreign financial accounts, own assets abroad, conduct business across borders, or have inherited assets from outside the United States, federal reporting requirements likely apply to your situation. At Crepeau Mourges, our Annapolis, MD tax lawyer advises U.S. citizens, residents, foreign nationals, and businesses on the planning, reporting, and disclosure obligations associated with international taxation. Founding partner Brandon N. Mourges is board-certified in Tax Law by The Florida Bar and holds an LL.M. in Taxation. Founding partner Brian J. Crepeau is a tax attorney, Certified Public Accountant, and Certified Fraud Examiner. We invite you to schedule a complimentary case review.

International Taxation Lawyer Annapolis, MD

International taxation refers to the body of federal rules that govern the U.S. tax treatment of cross-border activity, foreign-source income, and foreign-held assets. The rules apply broadly. They reach U.S. citizens and residents holding accounts abroad, foreign nationals conducting business in the United States, expatriates, recipients of foreign inheritances, and companies with foreign owners or subsidiaries.

The reporting framework is among the most demanding within the Internal Revenue Code. A single client may have obligations under the Foreign Bank Account Report regime, the Foreign Account Tax Compliance Act, and the various information returns governing foreign trusts, gifts, corporations, and partnerships. Many earlier tax planning and compliance decisions take on additional significance once a foreign element is introduced. An international taxation lawyer in Annapolis assists clients in identifying these obligations, addressing prior gaps, and structuring future activity in a defensible manner.

Types of International Taxation Cases We Handle in Annapolis

International taxation matters arise in a range of contexts, and our Annapolis tax attorneys advise clients across that range. Some matters are forward-looking and planning-oriented. Others arise from prior noncompliance or from an examination by the Internal Revenue Service.

• Foreign bank account reporting (FBAR). U.S. persons with foreign financial accounts exceeding the applicable threshold are required to file FinCEN Form 114 annually. Our work in this area addresses both current-year filings and the resolution of prior reporting gaps.
• Offshore voluntary disclosure and streamlined filing compliance. The Internal Revenue Service maintains several pathways for taxpayers seeking to address unreported foreign accounts and income. We assist clients in evaluating eligibility for streamlined procedures and other disclosure options, and in handling the offshore compliance process from beginning to end.
• Foreign asset reporting under FATCA. Form 8938 applies to U.S. persons with specified foreign financial assets exceeding the applicable threshold. We advise on the scope of the form, its interaction with other filings, and the resolution of prior nonfiling.
• Foreign corporations and partnerships. U.S. persons with ownership in foreign corporations or partnerships may be subject to reporting on Forms 5471, 8865, and related schedules. We address ownership analysis, classification questions, and the reporting itself.
• Foreign trust and inheritance reporting. Form 3520 applies to certain transactions with foreign trusts and to the receipt of significant foreign gifts and inheritances. The associated penalty exposure is substantial, and the rules are not intuitive. We advise on both current reporting and the resolution of prior gaps.
• Passive foreign investment company (PFIC) issues. Ownership of foreign mutual funds, foreign pension accounts, and similar investments often triggers PFIC reporting on Form 8621. We advise on the available elections and the preparation of the related computations.
• International estate, gift, and inheritance matters. Estates with foreign beneficiaries, non-U.S. citizen surviving spouses, or foreign assets require specialized planning that often overlaps with estate and gift taxation work.
• FIRPTA compliance. Foreign sellers of U.S. real property and the purchasers acquiring such property are subject to withholding obligations under the Foreign Investment in Real Property Tax Act. We advise on withholding, exemptions, and applications for reduced withholding or refund.
• Pre-immigration and expatriation tax planning. Individuals preparing to become U.S. residents, or U.S. citizens and long-term residents preparing to relinquish that status, face significant tax consequences requiring planning before the event.
• International tax examinations and disputes. The Internal Revenue Service examines international reporting positions with notable frequency. These matters often progress into formal tax controversy and disputes representation.

Why Choose Crepeau Mourges for International Taxation in Annapolis, MD?

At Crepeau Mourges, international taxation is a substantive component of our practice. The combination of advanced tax credentials and direct experience with the Internal Revenue Service and Department of Justice positions the firm to handle the planning, compliance, and disclosure phases that often arise within the same matter.

Substantive International Tax Background

Brandon N. Mourges holds an LL.M. in Taxation from the University of Baltimore School of Law and a Bachelor of Science in Economics from The Wharton School of the University of Pennsylvania. He is board-certified in Tax Law by The Florida Bar. Mr. Mourges has advised clients on a substantial number of international reporting matters, including offshore voluntary disclosures, streamlined filing compliance submissions, and the preparation of returns involving Forms 5471, 8865, 8938, 3520, 8621, and 1040-NR. He has been recognized as a Rising Star by Super Lawyers and on Benchmark Litigation’s “40 & Under Hot List.”

Coordinated Counsel for Cross-Border Matters

Brian J. Crepeau advises clients with international tax exposure as a tax attorney, Certified Public Accountant, and Certified Fraud Examiner. He earned his Juris Doctor at American University, Washington College of Law. His background supports the income analysis, recordkeeping, and forensic dimensions that frequently accompany international examinations. Our work as Annapolis tax lawyers extends from initial cross-border planning through compliance, disclosure, and subsequent representation in any examination or dispute.

Understanding International Taxation Cases

Reporting Obligations, Tax Liability, and Disclosure Considerations

A typical international taxation engagement involves several interrelated components: the identification of the relevant reporting obligations, the calculation of the related tax liability, and the evaluation of any prior gaps that may require disclosure. These components are rarely addressed in isolation. The discovery of an unreported account during a single year’s planning conversation often leads to a comprehensive review of prior years. A representative engagement may address the following:

• Identification of all U.S. reporting obligations applicable to the client’s foreign accounts, assets, and entities
• Quantification of any related income tax, including income from foreign accounts, foreign corporations, and foreign trusts
• Evaluation of available disclosure programs, including streamlined filing compliance procedures and other administrative pathways
• Analysis of penalty exposure under the FBAR, FATCA, and information return regimes
• Coordination of the planning and reporting for any foreign businesses or trusts in which the client has an interest
• Treatment of estate, gift, and inheritance matters where foreign assets or beneficiaries are involved

Each of these components informs the others. The choice of disclosure pathway depends on the underlying facts. The penalty exposure depends on the conduct that gave rise to the gap. The income tax consequences depend on the specific assets and entities involved. Analysis of any one element in isolation is rarely productive.

What Are Some Important Aspects in Your International Taxation Case?

Several considerations consistently shape the resolution of an international tax matter. Each warrants careful evaluation early in the engagement.

• The scope and duration of the prior reporting gaps, if any
• The nature of the underlying conduct, including whether positions were taken intentionally or in reliance on the advice of others
• The character of the foreign assets, including whether they are held directly or through entities or trusts
• The availability of foreign tax credits or treaty provisions that may reduce the U.S. tax liability
• The interaction of the international issues with any concurrent estate, gift, or business matters

We address each of these considerations during the initial consultation. The goal is to provide a candid assessment of the matter before recommending a disclosure pathway or planning approach.

International Taxation Case Timeline

Matters in this area follow varied timelines depending on whether the engagement is forward-looking or remediation-focused. The expected course of the matter is discussed at the outset and revisited as circumstances develop.

• Initial consultation and review of the client’s foreign assets, accounts, and activities
• Document collection, including foreign account statements, entity records, and prior U.S. tax returns
• Identification of reporting obligations, planning opportunities, and any required disclosure pathway
• Preparation of returns, information forms, and any disclosure submissions
• Representation in any subsequent examination, interview, or related proceeding

A current-year planning engagement may resolve within several weeks. A streamlined filing or other disclosure matter may extend over many months, particularly where the prior reporting gaps cover multiple years.

What Should You Bring to Your International Taxation Consultation?

Please bring whatever documentation you can readily assemble. Additional records may be requested following the initial consultation.

• A summary of all foreign financial accounts, including the institution, country, and approximate balances over the relevant years
• A summary of any foreign business interests, trusts, or other entities
• Prior U.S. tax returns, particularly any years in which foreign income or assets were not fully reported
• Any correspondence received from the Internal Revenue Service regarding international reporting

Most consultations last approximately one hour. At its conclusion, you will have a clearer understanding of your reporting obligations, the available pathways, and the recommended next steps. The case review is provided without charge, and there is no obligation to retain the firm afterward.

Important Maryland Legal Resources for International Taxation Cases

Federal authorities publish guidance that may assist individuals and businesses in understanding international reporting requirements, disclosure pathways, and applicable forms. Clients working with a tax lawyer in Annapolis on an international matter may find these references useful as starting points, though they do not substitute for legal advice on a specific situation.

• The Internal Revenue Service maintains a dedicated section addressing the obligations of international taxpayers.
• The Financial Crimes Enforcement Network administers the FBAR regime through FinCEN Form 114.
• The IRS publishes information on the streamlined filing compliance procedures available to eligible taxpayers with unreported foreign accounts or assets.
• The IRS provides guidance on FATCA reporting for both individuals and financial institutions.
• The U.S. Department of the Treasury publishes the texts of U.S. income tax treaties with foreign jurisdictions.

These resources are useful as preliminary references. They are not a substitute for case-specific counsel. We consult them regularly in the course of our international tax work and recommend them as reliable points of orientation.

Reach Out to Crepeau Mourges to Schedule a Consultation

International tax matters rarely become less complicated with the passage of time, and the associated penalty regimes are among the most significant within the Internal Revenue Code. Contact us to schedule a complimentary case review with an Annapolis, MD tax attorney who advises individuals and businesses with cross-border interests. We will identify the relevant obligations, outline the available pathways, and explain what to expect going forward.