International Tax Matters

International Tax Matters

Expanding business beyond your country of origin? That’s often necessary for growth, but with international presence comes international taxes. At Mixon Tax Law, comprehensive international tax preparation services are tailored to unique client needs.

Let’s be direct about international tax work—this is where people get into serious trouble fast. Clients have faced penalties that were literally more than their houses were worth, all because they didn’t know about some obscure filing requirement. The IRS doesn’t care that taxpayers were unaware; ignorance isn’t a defense when it comes to international tax compliance.

What Are International Tax Matters?

Business Expansion

International tax isn’t like regular tax work. The rules are different, the penalties are harsher, and the IRS has gotten incredibly aggressive about enforcement in recent years. They’re using information sharing agreements with foreign governments to hunt down unreported accounts and assets.

What makes this area so dangerous is that penalties often have nothing to do with how much tax is actually owed. Miss filing an FBAR? That’s almost thirteen thousand dollars per account, even when taxpayers don’t owe a penny in actual taxes. Washington has decided international compliance is their new favorite weapon, and they’ll wreck financial lives just to prove they can.

The firm’s international tax blog covers technical details, but here’s what needs to be understood: international tax compliance is not optional, it’s not forgiving, and it’s getting more complicated every year.

International Tax Attorney Services

International Tax Planning for Individuals and Businesses

We live in a highly globalized world, and it has opened a plethora of new opportunities for all types of businesses. New challenges also arise with new opportunities. Challenges such as international tax compliance. The complexities of foreign legal systems, combined with changing U.S. immigration laws, make tax compliance very complicated for businesses. This has made international tax advisory services a must for anyone looking to explore global markets. If business owners are looking to expand operations and are uncertain about international tax laws, they’re not alone. Fortunately, Mixon Tax Law offers comprehensive international taxation services, which include:

Cross-border Business Support

International business involves dealing with multiple tax systems that often conflict with each other. The firm helps companies navigate transfer pricing rules, take advantage of tax treaties, and avoid the various anti-avoidance traps that can turn profitable international operations into tax nightmares.

Outbound and Inbound Tax Planning for US-based Clients

Whether clients are U.S. businesses expanding internationally or foreign entities investing in the United States, proper tax planning is essential for optimizing global tax positions while maintaining compliance in all relevant jurisdictions.

Resolving Tax Controversies Involving International Compliance Issues

International tax disputes often involve multiple jurisdictions and complex procedural requirements. Mixon Tax Law represents clients in IRS examinations, appeals, and litigation involving international tax issues, FBAR penalties, and FATCA compliance matters.

As a business owner, there's already a lot to handle. Don't add international tax compliance to the list. Let international tax specialists handle the compliance concerns, so business owners can focus on what matters: expanding their businesses.

Avoid Offshore Penalties with Our International Tax Service

At Mixon Tax Law, international taxation consultants offer representation for the following international tax compliance matters:

Offshore Voluntary Disclosure & Tax Amnesty

Compliance is a major concern when dealing offshore. There is always a risk of IRS fines and penalties. If a U.S. person has unreported offshore accounts, assets, investments, or income, the penalties can be devastating. The firm helps clients minimize or avoid these fines and penalties through effective international tax planning. Years of experience help clients safely get to compliance using approved tax amnesty and voluntary disclosure programs to their advantage.

FATCA & FBAR Compliance

FBAR (Foreign Bank and Financial Reporting) requires taxpayers to submit FinCEN Form 114 if they hold a specified interest in a non-U.S. bank account. The FATCA (Foreign Account Tax Compliance Act) reporting requirement necessitates taxpayers to report specified foreign financial assets using Form 8938. The U.S. government and IRS have made enforcement a top priority for FBAR and FATCA reporting. These compliance requirements are nightmares to navigate alone. Clients need an attorney who's actually dealt with FBAR and FATCA issues for both individual taxpayers and businesses, because the rules and penalties are different for each.

Reporting Gifts from Foreign Persons

Foreign gifts over certain amounts trigger Form 3520 filing requirements. People have been hit with massive penalties for not filing this form, even when they didn't owe a dime in taxes on the gift itself. The IRS doesn't care—miss the form, pay the penalty. Oftentimes, taxpayers realize too late that they should have filed the form, leading to the maximum penalty, which in such cases is 25% of the value of the gift. Having an international tax advisor by your side can help avoid this penalty.

Filing Foreign Corporation & Partnership Information Returns

If taxpayers have ownership or interest in a foreign corporation or partnership, they have several reporting and filing requirements. Fulfilling these requirements demands attention to detail and expert legal insights to avoid unnecessary taxation issues. Taxpayers may have to file Form 5471 or Form 8865 according to their unique situation. They may be subject to fines and penalties if they do not file these forms on time. International taxation experience helps clients accurately file these forms to avoid legal troubles.

Avoiding and Minimizing Offshore Penalties

Taxpayers may sometimes receive notices such as CP15 notices, 504 notices, or audit requests for international taxation-related penalties. These penalties can be prevented, minimized, or abated using international tax preparation services and penalty defense strategies.

Foreign Trust Compliance

U.S. beneficiaries of foreign trusts face complex reporting obligations that can result in severe penalties for non-compliance. Mixon Tax Law helps clients understand their obligations and ensure proper reporting on Forms 3520 and 3520-A.

Treaty Benefits and Planning

International tax treaties can provide huge savings on cross-border deals—lower withholding taxes, exemptions from double taxation, that kind of thing. But the IRS and foreign governments don't just hand out these benefits. The firm works with clients to structure transactions properly and handle all documentation requirements to actually get the treaty protection.

Transfer Pricing Documentation

Multinational businesses must maintain proper transfer pricing documentation to support intercompany transactions. Mixon Tax Law assists with transfer pricing studies, documentation requirements, and defense of transfer pricing positions during IRS examinations.

Frequently Asked Questions

Foreign Account Reporting Requirements

Two different forms, two different agencies, two different sets of penalties. FBAR is filed with FinCEN if foreign accounts hit $10,000 total at any point during the year. FATCA is Form 8938 filed with tax returns for specified foreign assets—thresholds vary based on filing status and where taxpayers live. Taxpayers might need both, and missing either can be expensive.
That’s not an automatic disaster, but they’re definitely in hot water if they don’t act fast. FBAR penalties can destroy people—$12,000+ per account for simple mistakes, half the account balance if the IRS thinks it was intentional. The only way out is immediate compliance and a compelling argument for penalty reduction.
It depends on specific situations and which approach gets used. Clients might pay anywhere from several thousand to thirty thousand in fees, but that’s nothing compared to what they stand to lose. Proper representation has kept people from financial ruin.
Yes, and they’re getting better at it every year. Banks worldwide are reporting account information directly to the IRS. Trying to hide foreign accounts is incredibly risky—it can turn a civil penalty case into a criminal prosecution. Don’t even consider it.

Voluntary Disclosure Programs

That’s the critical question, literally in some cases. Streamlined has lower penalties but requires taxpayers to certify that violations were non-willful. Get that wrong, and they could face perjury charges. Traditional disclosure is safer if there’s any question about willfulness, but the penalties are much higher. This decision can make or break cases.
Then streamlined procedures are off the table, and other strategies need exploration including traditional voluntary disclosure. The IRS takes willfulness very seriously—they’ll dig into education, experience, and circumstances to see if taxpayers should have known better. It’s not a decision to take lightly.
Streamlined procedures usually take 6-12 months if everything gets done right the first time. Traditional disclosure can take 1-2 years or more. The IRS is slow, and they’re thorough. Any mistakes or missing information just delays things further, which is why getting it right initially is so important.
That’s strongly discouraged. Too many people make their situations infinitely worse by trying DIY international tax compliance. The penalties are severe, the rules are complex, and the IRS doesn’t give second chances with voluntary disclosure programs. Taxpayers get one shot—don’t waste it.

Business International Tax Issues

Probably, and ignoring it is dangerous. Form 5471 has different filing requirements depending on ownership level and involvement, but penalties start at $10,000 and can go much higher. People have been hit with $60,000+ penalties for small foreign corporations that weren’t even profitable.
CFC rules can force taxpayers to pay U.S. tax on foreign corporate income that they never actually received. It’s one of the government’s tools to prevent profit-shifting to low-tax countries. The rules are incredibly complex, and getting them wrong can result in huge tax bills plus penalties.
Very carefully. The IRS expects related-party transactions to be priced as if they were between unrelated parties. If they disagree with pricing, they can make massive adjustments that result in double taxation, penalties, and years of controversy. This area requires serious expertise and documentation.
GILTI is Washington’s tool to address international tax planning. It creates current U.S. tax liability on foreign income taxpayers might never actually receive. The calculations are horrendously complex, and plenty of taxpayers got hit with shocking tax bills when this kicked in without proper planning.

Individual International Issues

Once the reporting threshold is hit, usually one hundred thousand from someone foreign, taxpayers must file Form 3520. Skip it and the penalty can be 25% of the gift. Imagine receiving $200,000 from an overseas grandmother and owing the IRS fifty grand in penalties because the right form wasn’t filed. Taxpayers can receive a $200,000 gift and face a $50,000 penalty just for not filing a form, even though they don’t owe any tax on the gift.
Treaties can provide real benefits—lower withholding taxes, tie-breaker rules for residency, protection from double taxation. But claiming treaty benefits usually requires specific forms and procedures. It’s not automatic, and getting it wrong can cost those benefits plus create other problems.
Don’t pay anything until it’s reviewed. International tax penalties can often be reduced or eliminated with proper representation, but responses need to be made within their deadlines. Penalties that seemed hopeless have been reduced to zero or minimal amounts, but timing is critical.

Why Choose Mixon Tax Law for International Tax Matters

International tax work requires someone who’s actually done this before and knows where all the landmines are buried. Clients don’t want to learn about FBAR penalties the hard way, and they definitely don’t want to experiment with voluntary disclosure procedures. Learn more about Phillip’s background and understand why this approach has kept so many clients out of serious trouble.

His CPA background helps him understand technical requirements and navigate complex international financial structures. The legal training is what saves clients from catastrophic penalties and criminal exposure. International tax isn’t just about compliance—it’s about survival when the government decides to make an example out of someone.

Here’s what Mixon Tax Law brings to international tax situations:

Dual Professional Expertise

CPA knowledge of complex international reporting combined with legal advocacy for penalty defense provides comprehensive protection.

Previous Employer's Firm Experience

M&A background at a previous employer's firm provides sophisticated understanding of international tax structures and compliance requirements.

Specialized Focus

Concentrated practice in international tax compliance and controversy matters ensures deep expertise in this complex area.

Penalty Defense Experience

Proven track record in international penalty abatement and voluntary disclosure programs protects clients from devastating financial consequences.

Business Understanding

Practical knowledge of how international tax rules affect real business operations translates into effective compliance strategies.

Client Success Stories

International tax problems can create devastating financial and legal exposure, but experienced representation often makes the difference between manageable compliance costs and catastrophic penalties. Read detailed client testimonials to see the results achieved for individuals and businesses facing international tax challenges.

Meet Your International Tax Attorney

International tax matters require someone who understands both U.S. tax law and the practical realities of cross-border compliance. Phillip’s background combines previous employer’s firm international tax experience with focused legal practice in tax controversy and compliance matters.

Meet Attorney Phillip Mixon, a seasoned tax attorney in Houston with years of experience handling complex tax matters. From resolving IRS collections to providing tax planning for businesses, his wealth of experience and professional background guarantee that clients receive reliable legal representation in all tax-related matters.

He’s not just a local tax attorney; he’s also a Certified Public Accountant (CPA), a dual qualification that sets him apart in the field of tax law. Holding both his CPA license and Texas bar license, he offers a unique blend of legal and financial acumen that benefits clients in multifaceted ways.

Visit the attorney profile to learn more about qualifications and approach to international tax compliance and controversy representation.

A smiling man with a beard wearing a tie, exuding confidence and professionalism.

Get Expert Help with International Tax Issues

International tax problems get worse every day they’re ignored, and the IRS isn’t getting more forgiving. If taxpayers have unreported foreign accounts, unfiled international forms, or received penalty notices, call the Houston office immediately.

Call (713) 814-4737 to discuss your situation. Phillip handles these consultations personally because international tax cases often involve potential criminal exposure that needs immediate assessment.

Whether dealing with unfiled FBARs, missed foreign corporation reporting, or considering voluntary disclosure, don’t try to navigate this alone. Too many people destroy their financial lives by handling international tax problems incorrectly. The government has made international compliance a priority, and they’re willing to impose severe consequences to prove their point.

If international tax help is needed, don’t wait until penalties become insurmountable. Schedule your consultation today and let Mixon Tax Law help resolve these matters before they become financial disasters.

International Tax Resources and Updates

International tax law changes frequently, with new reporting requirements, penalty provisions, and compliance programs regularly introduced. Staying informed about these developments is crucial for maintaining compliance and avoiding costly penalties.

The firm’s international tax blog regularly covers developments in international tax law, compliance requirements, and practical strategies for managing international tax obligations. These resources complement the personalized legal advice provided to clients facing specific international tax challenges.

Business Tax | IRS | Local Tax | International Tax

Phillip also maintains active involvement in international tax organizations and regularly attends conferences to stay current on developing issues that affect clients’ compliance obligations and planning opportunities.

Experienced International Tax Representation You Can Trust

Phillip’s career began at one of the Big Four accounting firms, where he honed his skills in the Mergers and Acquisitions (M&A) tax department. At that firm, he played a pivotal role in advising clients on the tax implications of corporate transactions, ensuring compliance, and optimizing tax outcomes during high-stakes deals. This experience provided invaluable insights into the complexities of tax law and corporate finance, which he now leverages in current practice.

Today, he focuses practice on IRS and state controversy matters, including the complex international tax issues that arise in our increasingly global economy. His extensive background allows him to handle disputes with taxing authorities expertly, whether they involve domestic or international tax compliance matters.

Whether it’s negotiating with the IRS on international penalty matters, managing voluntary disclosure programs, or navigating complex international tax regulations, clients can trust they are in capable hands.