Verni Tax Law

Thailand Tax Services for U.S. Expats

If you are a U.S. expat living in Thailand and need an attorney with International experience to solve even the most sophisticated tax problems, contact Anthony Verni for an initial consultation. With over 20 years of experience, Anthony delivers successful results to clients living in and outside of the U.S.

Claim Your Free Consultation

When the IRS Comes Knocking, Your Future
Is on the Line

Over 2,667 criminal tax investigations were initiated by the IRS last year, with a conviction rate of 90%.

It starts with a letter, then a request for a meeting, and suddenly you're facing allegations that could lead to financial devastation or even prison time. The government has unlimited resources and years to build the case against you.
In these critical moments, having the right tax fraud attorney can mean the difference between freedom and severe penalties.

Your Tax Matter Deserves Focused, Skilled Legal Representation!

Verni Tax Law, with offices in New Jersey and South Florida, is equipped to handle a wide range of tax fraud matters with precision and care. Serving clients nationwide, including U.S. taxpayers abroad or with international business ties.
Our expert team can guide you through investigations involving

Tax evasion and fraud

Filing false or misleading tax returns

IRS audits and criminal tax investigations

Failure to file or pay taxes

Failure to collect or remit employment taxes

Offshore account disclosures and foreign asset reporting violations

Submission of false documents or misstatements

Get the skilled defense you need. Speak with our tax fraud attorney today to protect your rights and manage your case effectively.

Is the IRS Investigating You for Criminal Tax Fraud?

Many taxpayers don’t realize there’s a critical difference between a civil tax audit and a criminal tax investigation.

Civil cases focus on recovering unpaid taxes, interest, and civil penalties.

Criminal cases are about punishment; they carry the risk of felony charges, prison time, and lasting reputational damage.

Key warning signs that suggest the IRS is conducting a criminal investigation:

  • IRS agents identify themselves as part of the Criminal Investigation Division (CID).
  • You receive a subpoena, search warrant, or formal summons.
  • Investigators contact you directly, bypassing your accountant or tax preparer.
  • You’re asked detailed questions about your intent or knowledge, not just your numbers.
  • There’s evidence of parallel investigations, for example, a civil audit and a criminal inquiry happening at the same time.

No matter if it's civil or criminal, Verni Tax Law has the expertise to protect you!

We specialize in identifying potential risks early, before they escalate into serious IRS investigations. If your case does reach criminal or civil investigation, our team uses in-depth forensic analysis, expert negotiation strategies, and precise legal positioning to push back against IRS tactics.
Contact Verni Tax Law Today!

Know Why Verni Tax Law Is the Right Choice for Your Tax Fraud Defense

  • Customized risk profiles based on your specific tolerance level
  • Expertise in FBAR and FATCA compliance for foreign asset holders
  • Proprietary case database for accurate outcome assessment
  • Industry-specific defense strategies for your business sector
  • Direct access to Anthony Verni with a 24-hour response guarantee

Act Before the IRS Builds Its Case!

Voluntary Disclosure Could Be Your Best Option

The longer you wait, the fewer options you have. By the time the IRS contacts you, they may already have a case built, with limited room for negotiation.

If your filings involve unreported income, offshore accounts, or willful errors, the IRS Voluntary Disclosure Program may be the last opportunity to avoid prosecution and resolve your tax issues discreetly.

Verni Tax Law uses this program as part of a broader defense strategy designed to protect your rights, reduce penalties, and bring you into compliance without triggering criminal charges.

Let’s determine if this is the right step for you; start with a confidential consultation today.

FBAR Penalties for U.S. Expats in Thailand

What is FBAR?

An FBAR (Foreign Bank Account Report) is required to be filed by U.S. citizens, permanent residents and legal entities with an interest or signature authority over foreign financial accounts that have an aggregate balance exceeding $10,000.

Foreign financial accounts include but are not limited to banks accounts, brokerage accounts, mutual funds, life insurance policies with cash value, and indirect interests in foreign financial assets through an entity. The FBAR is separate from your income tax filing, and the due date is June 30th of each year. Extensions are not allowed. FinCen Form 114 can only be filed electronically.

FBAR Penalties

There are two types of FBAR penalties applicable: Non-Willful and Willful. It should be noted that the penalties are assessed per account, and not per FBAR. Additionally, the FBAR penalties are assessed for each year there is a violation. For example, if you have 3 accounts that have not been reported for 4 years, there could be 12 separate penalties assessed. Each year you didn’t file is a separate violation.fbar thailand penalties levied by the IRS can be civil and crimial punishments

Criminal penalties for FBAR violations are even more intimidating, including a fine of $250,000 and 5 years of imprisonment. If the FBAR violation occurs while violating another law the penalties are increased to $500,000 in fines and/or 10 years of imprisonment.
The IRS looks at such issues – how other accounts are treated, etc., in determining when and if penalties are to be applied, with particular attention paid to willfulness as a factor in whether a penalty is warranted.

Penalty for failure to file a Statement of Specified Foreign Financial Assets (Form 8938)

A Statement of Specified Foreign Financial Assets is included with your income tax filing. All U.S. persons who receive financial gains from foreign financial accounts that have an aggregate balance exceeding certain thresholds are required to file Form 8938. The maximum penalty for failing to file Form 8938 is $60,000 for each foreign asset that you failed to report.

FATCA & U.S. Expats in Thailand

FATCA is causing much anxiety among U.S. expat communities around the world. Roughly 110 countries are either on-board with FATCA or have active discussions with the United States. FATCA stands for Foreign Account Tax Compliance Act. Under FATCA, foreign banks are required to report account information owned by U.S. citizens to the IRS.
As of June 24, 2014, local Thailand banks will have to report account information of U.S. taxpayers to the tax authority in Thailand. This information will be sent directly to the IRS.
Thailand did not meet its June deadline to forge a Foreign Account Tax Compliance Act Model 1 intergovernmental agreement. However, Thai financial institutions have entered into voluntary contractual agreements with the U.S. IRS and have agreed to the terms of the FATCA.

Thai financial institutions including banks, custodial institutions and life insurance companies—either have to chose to participate in the program by registering with the IRS and agreeing to the terms of FATCA or face a withholding tax on any U.S. source income they receive.

How does FACTA impact Expats with Thailand bank accounts?

Expats living in Thailand or abroad are required to report the foreign earned interest on their U.S. income tax return. Before FATCA, the reporting of foreign earned interest was based on an honor system. With FATCA, IRS computers will receive your account information, and will reconcile it against your tax return. Identifying delinquent taxpayers will become an automated process.

The social security number is the critical information captured on the W-9. With this information, the IRS can match foreign bank account information with a U.S. tax return. There is no legal requirement to complete the W-9. However, your Thailand bank will probably close your account if you do not comply.

In addition to reporting foreign earned interest, you may need to file informational reports FBAR and Form 8938.

A final word: It is absolutely in your best interest to become tax-compliant in order to avoid paying huge fines and face possible jail time due to FBAR penalties. When in doubt, speak to a legal professional experienced in expatriate tax matters.

For more information on FBAR Representation, click here.

Hear from relieved
taxpayers who trusted Verni Tax Law

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

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.

Douglas R.

Osaka, Japan

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.

Phil Y

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

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.

Yassin and Eva, B.

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

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

cover the general 6-year criminal statute of limitations, exceptions for continuing conspiracies, and the unlimited period for civil fraud penalties.

should detail specific signs like special agent visits, third-party contact notices, and grand jury subpoenas.

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.

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.