Experienced Tax Attorneys

Call Us Confidentially Now: 202-349-4033

Call us confidentially now:

Confidential & Experienced Tax Lawyers

Get Help Now: 202-349-4033


Experienced former IRS attorneys helping businesses and individuals with offshore bank accounts at UBS come into compliance with Foreign Bank Account Reporting (FBAR) regulations, including the Foreign Accounts Tax Compliance Act (FATCA), IRS Voluntary Disclosure policies, the Offshore Voluntary Disclosure Program and the Streamlined Offshore Disclosure Program. 


The Foreign Account Tax Compliance ACT, also known as FATCA, came into effect on July 1st, 2014. The purpose of this law is to target and reduce foreign tax evasion and fraud by requiring U.S. taxpayers to comply with IRS tax law. The U.S. government has long struggled to track foreign accounts. For decades, these undisclosed foreign accounts meant huge annual losses for the IRS in penalties and tax revenue. So, to address the issue of undisclosed foreign accounts head on, the government created the FATCA legislation. 

Since 2014, countless assets in foreign financial institutions have been frozen. As a U.S. taxpayer, resident or address holder with foreign accounts, you yourself may have received a FATCA letter. If so, it’s important to remember that a FATCA letter’s purpose is to help the bank understand if the letter’s recipient has successfully complied with IRS FATCA laws. You’ll need to be prepared to prove that you have, indeed, followed all necessary tax filing procedures. FATCA letters may come from either the financial institution or the government (IRS or DOJ). If the letter is from a government institution, this means that a severe civil or criminal investigation is already underway. In these cases, it is especially crucial for account holders to act quickly and retain legal counsel.  

If you have an offshore account at the Swiss bank UBS, Thorn Law Group can help you complete the necessary protocols to report your assets to the IRS or DOJ. As an experienced tax lawyer who has successfully resolved hundreds of voluntary disclosure claims against taxpayers, I can help you determine which disclosure program is best for you – the Offshore Voluntary Disclosure Program (OVDP) or the IRS Streamlined Offshore Disclosure Program. No two tax situations are the same, but my goal never changes – to help you avoid financial penalties and potential IRS criminal charges.                                                                    


According to FATCA regulations, taxpayers with foreign financial assets that exceed $50,000 must disclose those assets on Form 8939 Statement of Specified Foreign Financial Assets, and include this with their yearly tax filing. However, U.S. taxpayers filing a joint tax return or who live abroad have higher asset thresholds. 

There are five general categories of taxpayers who are impacted by FATCA legislation: 

  • US Citizen - All US Citizens with foreign assets over $50,000 must report.
  • Legal Permanent Resident - If you have relocated back to another country, you are still required to report.
  • Foreign National - Substantial Presence Test - The test is basically if you were physically present in the United States for 31 days and 183 days during a three-year period. You can see the full test on the IRS website.
  • Long-Term Green Card Holders - Those that did not properly relinquish their Green Card.
  • Expat - If you are a US citizen living abroad. 

If you’ve received a UBS FATCA letter, then time is of the essence. Failure to report your assets could result in steep monetary penalties. What’s more, if the IRS or DOJ believes that you willingly neglected to disclose this information, they can launch a criminal investigation. The result of such an act can lead to time in prison. Fortunately, our tax lawyers are ready and able to help you right now.   


Receiving a FATCA letter is extremely nerve-racking, but having an experienced tax attorney on your side can make all the difference. At Thorn Law Group, our team is comprised of former IRS attorneys who know exactly what the agency looks for and how to quickly and successfully resolve Foreign Bank Account Reporting (FBAR) issues. If you have an account with UBS, we can help guide you through the tax compliance process. We have successfully saved clients millions of dollars and helped them avoid civil and criminal penalties, and can do the same for you.  


Receiving a FATCA letter is never great news. However, it does not mean that you will automatically be penalized. Thorn Law Group is here to help you report your assets and eliminate IRS civil and criminal penalties. To get the IRS off your back today, schedule a consultation with a tax attorney at (202) 349-4033 or complete our online contact form.

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Hear What Our Clients Have To Say

"Kevin Thorn, Managing Partner of Thorn Law Group, is an excellent adviser. My family and I are US citizens living in Europe and the US. Mr. Thorn helped us to understand our opportunities for international investments and estate planning issues so that my siblings and I may continue to further the growth of our businesses, to care for our aging parents and provide for our children. Mr. Thorn and his team were sensitive to our family's needs and helped us identify and understand our options and potential risks associated with US and international activity."
Elena Cardaropoli