FATCA Compliance Attorney Expert
IRS Foreign Account Reporting

If you're a U.S. taxpayer holding foreign financial assets, FATCA compliance is an essential The IRS imposes strict penalties for failing to disclose offshore accounts and specified foreign assets.

Schedule your free FATCA compliance assessment today.
At Verni Tax Law,
We help individuals and businesses across Miami, Newark, and beyond navigate FATCA reporting, Form 8938 filing, and penalty defense.
With 25+ years of experience and direct history with IRS, our firm provides strategic assistance tailored to your unique tax situation.
fatca compliance

IRS FATCA Enforcement is Costly

If you’ve failed to report foreign assets, even unintentionally, the IRS may hit you with:
  • $10,000–$50,000 in penalties per missed filing
  • 40% of any unreported foreign income
  • Criminal investigation for willful non-compliance
  • Account freezes, tax liens, or passport revocation
Many taxpayers don’t even realize they’re non-compliant until it’s too late. Filing the wrong form, or missing one, can trigger years of audits and financial scrutiny.

FATCA Reporting Compliance Assistance

We offer full-service support for individuals, businesses, and foreign entities with U.S. tax exposure.

Form 8938 Preparation

Accurate identification, valuation, and reporting of your offshore assets.

Voluntary Disclosure & Streamlined Filing

Bring your filings current while minimizing penalties through IRS-approved programs.

IRS Penalty Defense

Already received a notice? We build strong reasonable cause arguments and represent you in audits, appeals, and collections.

Dual FATCA & FBAR Compliance

We ensure you file both Form 8938 and FBAR forms correctly and timely to avoid duplicate or conflicting disclosures.

FATCA Compliance Requirements for U.S. Taxpayers

U.S. citizens, resident visitors, and certain non-resident taxpayers must report specified foreign financial assets if their value exceeds IRS thresholds.
Failure to do so could lead to audits, stiff penalties, and even criminal charges. Here’s what you need to know:
Specified Foreign Financial Assets
Assets subject to FATCA include:
  • Foreign Bank Accounts and Securities
  • Ownership in Foreign Partnerships or Corporations
  • Foreign Mutual Funds and Hedge Funds
  • Cryptocurrencies and Digital Assets Held Offshore
  • Foreign Life Insurance or Annuity Contracts
Even if assets are not generating income, they may still require reporting.

FATCA Compliance for Entities

U.S. taxpayers with ownership or involvement in FFIs or NFFEs face entity-level compliance obligations.

Foreign Financial Institution (FFI)

If you hold shares or have control in an FFI, be aware of these obligations:
  • Global Intermediary Identification Number (GIIN) Registration
  • Account Holder Due Diligence Protocols
  • Form 8966 Filing for FATCA Reporting
  • Acting as a Withholding Agent in some cases

Non-Financial Foreign Entities (NFFEs)

Not all foreign entities are exempt. We help clients:
  • Identify Substantial U.S. Owners
  • Secure Withholding Certificates
  • Qualify for Exemptions Where Possible
  • Prepare Ownership Documentation for FATCA Compliance

Intergovernmental Agreement (IGA) Compliance

We provide tailored guidance based on your country’s IGA status:
  • Model 1 vs. Model 2 IGA Differences
  • Reporting Responsibilities Under Local Law
  • Navigating Bilateral Information Exchange Protocols

Why Clients Choose Verni Tax Law

We offer end-to-end support for compliance and regulations.

20+ Years of IRS Audit Experience

We’ve handled hundreds of FATCA-related cases, from simple late filings to multimillion-dollar disclosures.

20+ Years of IRS Audit Experience

We’ve handled hundreds of FATCA-related cases, from simple late filings to multimillion-dollar disclosures.

Strategic, Confidential Representation

No outsourcing. No generic advice. Every client gets a clear, tailored legal strategy.

Dual-Credentialed: Attorney, CPA, and MBA

Combining legal authority with deep tax expertise to build audit strategies that stand up to IRS scrutiny.

  • When the IRS Comes Knocking, Your
    Future Is on the Line
  • Your Tax Matter Deserves Focused, Skilled Legal Representation!
  • Is the IRS Investigating You for Criminal Tax Fraud?
  • No matter if it's civil or criminal, Verni Tax Law has the expertise to protect you!
  • Know Why Verni Tax Law Is the Right Choice for Your Tax Fraud Defense
  • Act Before the IRS Builds Its Case!
  • Hear from relieved taxpayers who trusted Verni Tax Law
  • Have questions or need guidance?
  • Frequently Asked Questions
fatca compliance

IRS FATCA Enforcement is Costly

If you’ve failed to report foreign assets, even unintentionally, the IRS may hit you with:
  • $10,000–$50,000 in penalties per missed filing
  • 40% of any unreported foreign income
  • Criminal investigation for willful non-compliance
  • Account freezes, tax liens, or passport revocation
Many taxpayers don’t even realize they’re non-compliant until it’s too late. Filing the wrong form, or missing one, can trigger years of audits and financial scrutiny.

FATCA Reporting Compliance Assistance

We offer full-service support for individuals, businesses, and foreign entities with U.S. tax exposure.

Form 8938 Preparation

Accurate identification, valuation, and reporting of your offshore assets.

Voluntary Disclosure & Streamlined Filing

Bring your filings current while minimizing penalties through IRS-approved programs.

IRS Penalty Defense

Already received a notice? We build strong reasonable cause arguments and represent you in audits, appeals, and collections.

Dual FATCA & FBAR Compliance

We ensure you file both Form 8938 and FBAR forms correctly and timely to avoid duplicate or conflicting disclosures.

FATCA Compliance Requirements for U.S. Taxpayers

U.S. citizens, resident visitors, and certain non-resident taxpayers must report specified foreign financial assets if their value exceeds IRS thresholds.
Failure to do so could lead to audits, stiff penalties, and even criminal charges. Here’s what you need to know:
Specified Foreign Financial Assets
Assets subject to FATCA include:
  • Foreign Bank Accounts and Securities
  • Ownership in Foreign Partnerships or Corporations
  • Foreign Mutual Funds and Hedge Funds
  • Cryptocurrencies and Digital Assets Held Offshore
  • Foreign Life Insurance or Annuity Contracts
Even if assets are not generating income, they may still require reporting.

FATCA Compliance for Entities

U.S. taxpayers with ownership or involvement in FFIs or NFFEs face entity-level compliance obligations.

Foreign Financial Institution (FFI)

If you hold shares or have control in an FFI, be aware of these obligations:
  • Global Intermediary Identification Number (GIIN) Registration
  • Account Holder Due Diligence Protocols
  • Form 8966 Filing for FATCA Reporting
  • Acting as a Withholding Agent in some cases

Non-Financial Foreign Entities (NFFEs)

Not all foreign entities are exempt. We help clients:
  • Identify Substantial U.S. Owners
  • Secure Withholding Certificates
  • Qualify for Exemptions Where Possible
  • Prepare Ownership Documentation for FATCA Compliance

Intergovernmental Agreement (IGA) Compliance

We provide tailored guidance based on your country’s IGA status:
  • Model 1 vs. Model 2 IGA Differences
  • Reporting Responsibilities Under Local Law
  • Navigating Bilateral Information Exchange Protocols

Why Clients Choose Verni Tax Law

We offer end-to-end support for compliance and regulations.

25+ Years of IRS Audit Experience

We’ve handled hundreds of FATCA-related cases, from simple late filings to multimillion-dollar disclosures.

Direct IRS Negotiation

We work directly with IRS counsel and agents to resolve compliance issues efficiently.

Strategic, Confidential Representation

No outsourcing. No generic advice. Every client gets a clear, tailored legal strategy.

Dual-Credentialed: Attorney, CPA, and MBA

Combining legal authority with deep tax expertise to build audit strategies that stand up to IRS scrutiny.

Real People. Real Disputes. Resolved With Strategy.

Anthony was creative in helping me resolve some past issues in a way that they never became a problem so that is greatly appreciated and I feel confident I can now enjoy my retirement with peace of mind. Thanks for that.

Ken B.

Cebu City, Philippines

I came to Anthony Verni with FBAR issues. I was not sure what to expect and felt that I was going to be put in a difficult position financially as well as legally. My fears were unfounded and I was very satisfied with his professionalism and the outcome of my case.

Douglas R.

Osaka, Japan

Anthony’s help with Swift & Secure Systems Inc., CheckWare Workstations LLC and my personal taxes have been of great value. Since moving to Florida (and my Connecticut Accountant retiring) I have tried various other methods of keeping the accounting and taxes under control.

Phil Y

President, Swift & Secure Systems Inc., Boynton Beach, FL

I would like to thank Anthony N. Verni.   Mr. Verni has successfully represented us before the Internal Revenue Service. We had foreign bank accounts that we inadvertently didn’t report and we were subject to steep penalties. As a result his efforts, the FBAR penalties were waived by the IRS.
Thank You

Yassin and Eva, B.

Farmington Hills, Michigan

Have questions or need guidance?

I’m always available by phone, email, or Skype whatever’s easiest for you.

Take the first step and let me help fix the root of your tax problems.

Frequently Asked
Questions

As both an attorney and CPA with an MBA, I offer a rare combination of legal, accounting, and business expertise that most tax resolution firms cannot provide. Unlike other firms, I personally handle every case from start to finish. My boutique practice approach ensures meticulous attention to detail and customized strategies based on your specific risk profile, rather than applying one-size-fits-all solutions.

I represent individual taxpayers, trusts and estates, business entities, foreign financial institutions, trade associations, and professional entertainers. My boutique practice is committed to developing and implementing meaningful domestic and international tax strategies that yield maximum tax savings while minimizing risk.

Living in Thailand or any international location won’t limit your access to quality representation. I offer flexible scheduling for consultations, including early mornings, evenings, and weekends, to accommodate your local time. All meetings can be conducted via secure video conferencing, and I can represent you before the IRS without requiring your physical presence in the United States.

Yes, as a US taxpayer, you generally must report financial accounts that your foreign businesses maintain if you have signature authority or financial interest in those accounts and if the aggregate value exceeds $10,000 at any point during the year. I can help by:

  • Conducting a comprehensive review of your global business structure
  • Identifying all reportable accounts across your multiple businesses
  • Preparing the necessary FBAR filings
  • Addressing any past non-compliance through appropriate disclosure programs
  • Creating a sustainable compliance strategy for future years

I offer flexible consultation scheduling to accommodate clients worldwide. Initial consultations typically last 45-60 minutes and can be conducted by phone, secure video conference, or in person at my Princeton or Fort Lauderdale offices. 

To schedule, you can call directly at (561) 531-8809 or use the secure contact form on my website. All consultations are confidential and protected by attorney-client privilege.

These complex cases require a multi-faceted approach. I’ll first assess whether you qualify for the Streamlined Filing Procedures or need to pursue other disclosure options. Then I’ll develop a comprehensive strategy that addresses both issues simultaneously, ensuring all filings are consistent. 

My experience with the Offshore Voluntary Disclosure Program since 2009 provides valuable insight into how the IRS approaches these cases, allowing me to anticipate challenges and develop effective responses that minimize penalties while bringing you into full compliance.

My approach to tax dispute resolution is distinguished by three key elements:

  1. Comprehensive analysis: I conduct an exhaustive review of your financial documentation and tax history before developing any strategy, often revealing options and defenses that might otherwise be overlooked.
  2. Strategic negotiation: Rather than taking an adversarial stance with tax authorities, I focus on collaborative problem-solving when possible, which has repeatedly resulted in favorable settlements.
  3. Direct attorney involvement: I personally handle every aspect of your representation, ensuring that the expertise you’re paying for is actually applied to your case at every stage of the process.