Segal, Cohen & Landis

International Tax

28 attorney-written articles

Untangling Foreign Trust Rules with a Practical Guide to Form 3520 Penalties

Learn how to avoid or reduce a 3520 late filing penalty with IRS relief options, reasonable cause, and proactive compliance strategies.

Sep 14, 2026Approx. 12 min readRead →

International Taxation Attorneys Share Expert Advice

Expert international taxation attorney advice on cross-border compliance, FBAR, GILTI, audits, and global tax strategies.

Jun 19, 2026Approx. 14 min readRead →

Miami IRS Tax Attorney: International Tax, FBAR, and Federal Tax Debt in South Florida

Miami is one of the most internationally connected cities in the United States. Its location as a gateway to Latin America, the Caribbean, and Europe has created a uniquely complex tax environment — one where FBAR…

May 20, 2026Approx. 8 min readRead →

Form 3520 Penalties Explained — And How to Fight Back

6 min read Quick Summary Form 3520 penalties start at 5% of the foreign gift amount per month, capped at 25%. On a $400,000 gift, the maximum penalty is $100,000 — even if you owed zero tax. Penalties can be fought…

May 19, 2026Approx. 6 min readRead →

I Got a Large Gift From My Foreign Parents — Do I Have to Report It?

5 min read Quick Summary If you received more than $100,000 from foreign parents or relatives in a single year, you must file IRS Form 3520. The reporting deadline is the same as your tax return — typically April 15,…

May 19, 2026Approx. 8 min readRead →

Filing U.S. Taxes With a Foreign Employer — No W-2, No Problem

U.S. citizens working for foreign companies do not receive a W-2 but still owe U.S. taxes. This guide covers foreign wage reporting, self-employment tax, the Foreign Earned Income Exclusion, the Foreign Tax Credit, and…

May 18, 2026Approx. 13 min readRead →

TFSA Tax Rules for US Citizens in Canada — What Every Dual Citizen Needs to Know

U.S. citizens holding Canadian TFSAs face annual U.S. income tax with no foreign tax credit relief. Rev. Proc. 2020-17 does not exempt TFSAs. This guide covers PFIC risks, reporting requirements, and planning options.

May 18, 2026Approx. 10 min readRead →

Foreign Inheritance and U.S. Tax — What You Need to Know Before Accepting an Inheritance

When a Foreign Inheritance Creates U.S. Tax Obligations Receiving an inheritance from a family member abroad is both deeply personal and surprisingly complex from a U.S. tax perspective. If you are a U.S. citizen,…

May 18, 2026Approx. 8 min readRead →

Form 3520 vs Form 3520-A — What's the Difference and Do You Need Both?

Form 3520 is filed by U.S. persons to report foreign gifts and trust transactions. Form 3520-A is filed by the foreign trust itself. Learn the key differences in who files, deadlines, penalties, and what happens when a…

May 18, 2026Approx. 10 min readRead →

Form 3520 for Asian-American Families: Reporting Gifts From Parents in China, Japan, Korea, and India

If your parents abroad sent you money, is it taxable? Probably not — but you may still need to file IRS Form 3520. Learn the $100,000 reporting threshold, what counts as a foreign gift, and how to stay compliant…

May 18, 2026Approx. 12 min readRead →

Green Card Holders and the Foreign Gift Tax Trap: What LPRs Must Know

The Moment Your Green Card Changes Everything The day you received your green card, the IRS began treating you exactly like a U.S. citizen for tax purposes — with all the same reporting obligations, penalties, and…

May 18, 2026Approx. 10 min readRead →

FBAR Filing Requirements for Expats: The Complete Guide to Foreign Bank Account Reporting

Need help with a late FBAR, penalties, or complex foreign account situations? Our FBAR attorneys provide confidential consultations for U.S. taxpayers facing compliance issues or FinCEN enforcement. FBAR Filing…

May 18, 2026Approx. 9 min readRead →

IRS Passport Restrictions and Foreign Tax Debt: How to Get Your Passport Back

The IRS can restrict or revoke a U.S. passport for serious tax debt. Learn how foreign tax debt, FBAR penalties, back taxes, and expedited decertification work.

May 18, 2026Approx. 11 min readRead →

PFIC Tax Reporting: The Silent Tax Bomb in Your Foreign Investment Account

Reading time: ~9 min If you are a U.S. taxpayer with investments in foreign mutual funds, foreign ETFs, or pooled investment vehicles held outside the United States, there is a high probability that you own one or more…

May 18, 2026Approx. 10 min readRead →

How the IRS Voluntary Disclosure Program Works for Foreign Account Holders

If you have undisclosed foreign bank accounts, unreported offshore income, or unfiled international information returns—FBAR, Form 3520, Form 8938—you are already in the IRS’s crosshairs. The question is not whether…

May 18, 2026Approx. 7 min readRead →

Form 3520 Threshold 2025: Current Year Limits and Historical Table

The 2025 Form 3520 threshold is $100,000 for foreign individuals and $20,116 for foreign corporations. See the complete inflation-adjusted table from 2020–2026, aggregation rules, and penalty details.

May 18, 2026Approx. 8 min readRead →

How to Keep Your Offshore Accounts from Becoming a Shore Subject with the IRS

Resolve San Diego Offshore Tax Issues with FBAR, FATCA compliance, voluntary disclosure & penalty relief from expert San Diego tax attorneys.

May 1, 2026Approx. 9 min readRead →

Free Expat Tax Filing Options That Actually Work

Discover free expat tax filing online options that work: FEIE, FTC, FBAR, FATCA, extensions & streamlined procedures for US expats.

Apr 28, 2026Approx. 10 min readRead →

The Expat Tax Deadline Survival Guide

Master your expat tax filing deadline: June 15 extensions, FBAR/FATCA rules, state taxes & penalties. Stay IRS compliant abroad!

Apr 3, 2026Approx. 13 min readRead →

How to Handle Your US Taxes When Married to a Non-Citizen

Master foreign spouse tax filing: Learn residency tests, joint elections, filing options, and cross-border rules for US-Canada couples.

Mar 20, 2026Approx. 12 min readRead →

Expat Tax Guide for U.S. Citizens Living Abroad (2026)

Master filing expat taxes abroad: FEIE, FTC, FBAR, FATCA, deadlines & streamlined compliance for US citizens.

Mar 6, 2026Approx. 27 min readRead →

Bridging Borders: Dallas International Tax Attorneys for Your Assets

Secure your global assets. Find an expert international tax attorney Dallas to navigate complex US tax laws & avoid penalties.

Dec 16, 2025Approx. 14 min readRead →

Boston's International Tax Gurus: Who to Call for Global Tax Peace of Mind

Navigate complex global tax laws. A boston international tax attorney ensures compliance, avoids penalties, and secures your financial peace of mind.

Dec 1, 2025Approx. 12 min readRead →

Simplify Your Taxes: A Guide to Streamlined Filing

US taxpayer with foreign assets? Learn about Streamlined filing compliance to become compliant, avoid penalties, and gain peace of mind.

Nov 28, 2025Approx. 8 min readRead →

Don't Get FBAR-ed: A Guide to Foreign Account Reporting

Avoid FBAR penalties! Our guide to Foreign bank account reporting covers filing rules, deadlines, and how to correct past mistakes.

Nov 26, 2025Approx. 17 min readRead →

Non U.S. Citizens Filing Requirements and Tax Treatment

If you are not a U.S. citizen you may be wondering whether you need to file a tax return in the United States and to what extent you are required to pay federal income tax. Will you be required to pay tax on worldwide…

Jul 7, 2023Approx. 7 min readRead →

A Taxpayer’s Guide to Compliance Under FATCA

Under the Foreign Account Tax Compliance Act (FATCA), U.S. citizens, including Americans living abroad, are required to report their foreign assets to the Internal Revenue Service (IRS) if they exceed a certain…

Jun 15, 2023Approx. 6 min readRead →

The Complete Guide to Form 3520: Who Files, When, and What Happens If You Don't

The Complete Guide to Form 3520: Who Files, When, and What Happens If You Don’t Publishing Notes for SCL Recommended use: update and expand the existing SCL article at IRS Form 3520: Reporting Requirements Involving…

Apr 3, 2023Approx. 19 min readRead →
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