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 Compliance Legal Services, Tailored For You.
Verni Tax Law offers comprehensive FATCA legal services designed to secure your financial future.
We assist clients who:
- Have not filed required Form 8938 disclosures
- Received IRS notices or penalty assessments
- Own complex or high-value foreign assets
- Operate businesses with foreign financial accounts
- Need to coordinate FATCA and FBAR filings
Our tailored legal services prioritize timely compliance,
risk reduction, and strategic resolution of offshore tax matters.
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 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.
Get the Relief You Qualify For, And the Support You Actually Need
We believe in doing it right from the very beginning. That’s why we start by reviewing your case thoroughly—so we can find the best IRS relief option that fits your situation.
The IRS offers these programs, but getting approved takes more than just applying. It takes someone who understands how the IRS evaluates financials, eligibility, and intent.
And if one relief option doesn’t fit your situation, we pivot to the next best one, without losing momentum.
When the IRS denies your qualification, we don’t stop. We challenge their financial determinations, file appeals, and push back through every legal and procedural channel available.
Your Case is a Priority! Contact Anthony N Verni
Contact Us
FAQs
What is FATCA compliance?
FATCA compliance involves reporting foreign financial assets on Form 8938 if you exceed IRS thresholds. Non-compliance can trigger significant penalties.
What are the FATCA reporting thresholds?
U.S.-based individuals: $50,000 (single)–$150,000 (married).
Abroad: $200,000–$600,000 depending on filing status.
What is the penalty for not filing Form 8938?
Up to $50,000 plus 40% of unreported income; criminal charges may apply in willful cases.
Do I need a lawyer for FATCA compliance?
A FATCA attorney is highly recommended, especially if you’re behind on filings or face potential penalties.
What is the difference between FATCA and FBAR?
FATCA (Form 8938) covers more assets and is filed with your tax return; FBAR (FinCEN 114) covers bank accounts and is filed separately.
Can I file FATCA forms late without penalty?
Penalties may apply, but we can argue “reasonable cause” or pursue voluntary disclosure to reduce or avoid them.
How long does FATCA compliance take?
Simple cases: 2–4 weeks. Complex disclosures or penalty negotiations: 6–18 months.
