International Tax Litigation
- Attorneys in Freeman’s tax controversy and litigation practice have been named to U.S. News and World Report’s Best Lawyers in America list, recognized by Chambers & Partners as among the leading tax and litigation attorneys in the United States, including for fraud representations, and recognized as the “Leading Tax Controversy Litigation Attorney of the Year” for the State of Texas.
- Attorneys in Freeman’s tax controversy and litigation practice have been named to U.S. News and World Report’s Best Lawyers in America list, recognized by Chambers & Partners as among the leading tax and litigation attorneys in the United States, including for fraud representations, and recognized as the “Leading Tax Controversy Litigation Attorney of the Year” for the State of Texas.
- We regularly take on the nation’s biggest litigation firm: The Department of Justice. We bring a systematic approach to investigations, tax defense, and trial; and rewriting the odds in complex, criminal tax matters, one case at a time.
International Tax Litigation
Globalization is a fact of life in our modern economy, and cross-border activities have become the norm, not the exception. For many, that means that the risks of tax non-compliance have never been more real—and the threat of international tax penalties, never more clear.
We regularly represent clients in international tax and penalty litigation. We are hyper focused; responsive; and battle-tested, bringing big-firm talent, think-tank intellect, and strategic insight, along with substantive international tax know-how.
Freeman is a sophisticated tax litigation boutique, zeroed in on advancing our clients’ litigation interests and committed to delivering world-class counsel in the courtroom and beyond. And international tax litigation is our forte.
Our attorneys regularly counsel clients on international and offshore tax compliance, helping them manage, understand, and comply with the tax requirements related to foreign assets; engage in inbound and outbound cross-border transactions; and maintain ongoing business operations in foreign countries.
Best Lawyers® and U.S. News & World Report have recognized Freeman as a “Tier 1” Tax Law firm and our tax attorneys have garnered national recognition for their tax defense work, such as:
- The “Leading Tax Controversy Litigation Attorney of the Year” for the State of Texas
- U.S. News – Best Lawyers® Best Lawyers in America
- The Best Lawyers in America®, Chambers USA
Consistent with the national recognition of our tax practice, Freeman hosts the world’s largest international tax conference, focusing heavily on civil and criminal tax litigation developments in the United States and internationally. We also provide an intensive Tax Court preparation course, training tax attorneys across the nation for the Tax Court’s bar examination and providing tax advocacy and litigation skills.
In tax litigation, the right move at the right time can mean the difference between the right outcome and the wrong one. We begin thinking through the end game from day one. We sift through and evaluate the case, cultivating its thematic essence and distilling complex facts into clear and compelling narratives and defenses. We evaluate creative solutions and technical tax exceptions and strategies.
With recent legal developments such as the Foreign Account Tax Compliance Act (“FATCA”) and the expansion of Information Exchange Agreements among countries around the world, the flow of information and reporting to the IRS and the coordinated enforcement by taxing authorities has never been greater. That means that the risks of non-compliance have never been more real. Freeman Law can help businesses and individuals manage these critical tax risks and make sense of complex international tax compliance rules.
We assist clients with international information return compliance and penalties, including:
- Form 5471, Information Return of U.S. Persons with Respect to Certain Foreign Corporations
- Form 5472, Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business
- Form 8938 Statement of Specified Foreign Financial Assets
- IRS Form 3520 Reporting Transactions with Foreign Trusts and the Receipt of Foreign Gifts
- Form 3520-A, Information Return of Foreign Trusts With a U.S. Owner
- Form 926, Return by a U.S. Transferor of Property to a Foreign Corporation
- Form 8865, U.S. Persons and Foreign Partnerships
We represent clients with U.S. territorial tax issues, including Puerto Rico and the U.S. Virgin Islands, as well as tax issues related to “inbound” and “outbound” international tax, foreign trusts, foreign tax reporting penalties, cryptocurrency, transfer-pricing matters, offshore tax compliance disputes involving FBAR penalties and international information return penalties, and litigating novel issues and “issues of first impression.”
We combine unique litigation skills and experience with substantive international tax knowledge. Our attorneys are client-focused problem solvers. They are steeped in substantive tax expertise gained from years of experience in the trenches and provide sophisticated representation and penetrating legal acumen.
We are well-versed in high-stakes international tax litigation, and our attorneys are trial-ready and battle tested. We’re ready when you are.
Representative Matters
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Section 982 Formal Document Requests
Represented clients in successfully moving to quash section 982 Formal Document Requests.
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International Tax Audits
Represented clients in tax audits involving international assets and income.
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Form 3520 Tax Penalties
Represented clients in litigation involving the assessment of tax penalties related to foreign trusts and Form 3520 penalties.
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Tax Litigation
Represented clients in federal court regarding assessments related to international source income.
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FBAR Audits
Represented clients in audits involving FBAR and Form 8938 reporting.
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Tax Litigation
Represented clients in proceedings to quash international tax Formal Document Requests, seeking documentation regarding foreign accounts.
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IRS International Penalty Defense and Voluntary Disclosure
Represented client in IRS offshore voluntary disclosure, guiding client through an “opt out” and reducing penalties by hundreds of thousands of dollars through penalty defense.
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Tax Litigation; U.S. Virgin Islands
Represented client in Tax Court litigation, challenging IRS proposed assessment denying United States Virgin Islands (USVI) bona fide resident status and tax benefits; obtained concession from IRS and full tax benefits.
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Criminal Defense; U.S. Virgin Islands
Represented client in criminal tax prosecution and jury trial in U.S. Virgin Islands.
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Appellate; U.S. Virgin Islands
Represented client in USVI tax matter before the Third Circuit Court of Appeals, including oral argument.
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IRS High-Wealth Audits; Puerto Rico
Represented client in IRS “wealth squad” (Global High Wealth Industry Group) audit involving Puerto Rico Act 20/22 benefits; obtained “no-change” audit.
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IRS Tax Representation; Puerto Rico
Represented client in challenging IRS assessment denying Puerto Rico Act 20/22 benefits; obtained reversal and removal of full assessment.
