We advise on sophisticated cross-border tax matters where precision and judgment matter. Our practice focuses on structuring international activities for tax efficiency while managing regulatory risk in an increasingly scrutinized global environment.
Cross-border structuring for closely held businesses and private clients
U.S. tax considerations for inbound and outbound investments
Treaty-based planning and controversy
CFC, Subpart F, GILTI/NCTI, FDII and BEAT analysis
Offshore reporting and disclosure strategy (FBAR, FATCA)
Pre-immigration and expatriation planning
Coordination with foreign counsel in multi-jurisdictional matters
KNOW ALL OUR CAPABILITIES
Yes — if the combined value of your foreign financial accounts exceeded $10,000 at any point during the year, you must file an FBAR (FinCEN Form 114) with the Financial Crimes Enforcement Network. Depending on the value of your assets, you may also need to file Form 8938 (FATCA) with your tax return. Missing these filings can trigger substantial penalties, so many people with foreign accounts get legal guidance before filing.
If you have unreported foreign accounts, the IRS offers disclosure programs — such as the Streamlined Filing Compliance Procedures — that can dramatically reduce or eliminate penalties for taxpayers whose failure to file was non-willful. Coming forward voluntarily, with a tax attorney, is almost always better than waiting for the IRS to find the accounts through FATCA data. OCP Tax Law builds offshore reporting and disclosure strategies designed to bring clients into compliance while limiting exposure.
GILTI — renamed Net CFC Tested Income (NCTI) under the July 2025 tax law — is a U.S. tax on the earnings of foreign corporations that Americans control, designed to prevent shifting profits offshore. It applies if you own a controlling stake in a foreign company (a controlled foreign corporation, or CFC), and the rules changed meaningfully in 2025, including the shift from GILTI to NCTI and FDII to FDDEI. OCP Tax Law analyzes CFC, Subpart F, NCTI, FDDEI, and BEAT exposure and structures international activity to manage it.
Cross-border tax can be reduced through the right entity structure, use of tax treaties, careful income sourcing, and foreign tax credit planning — but the strategy has to be built before transactions happen and be defensible if the IRS reviews it. OCP Tax Law advises on inbound and outbound investment structuring, treaty-based planning, and coordination with foreign counsel for closely held businesses and private clients.
Both moving to and leaving the United States create major tax consequences, and the best time to plan is before the move, not after. Pre-immigration planning can reset the tax basis of your assets and reduce future U.S. tax, while expatriation planning addresses the “exit tax” that can apply to long-term residents and citizens who give up their status. OCP Tax Law handles pre-immigration and expatriation planning as part of its international tax practice.
Yes — the United States taxes its citizens and green card holders on worldwide income no matter where they live, though credits and exclusions can reduce or eliminate double taxation. You also generally still have foreign account and asset reporting obligations, such as the FBAR and Form 8938. A tax attorney can help structure your affairs so you stay compliant without overpaying.
YOUR TAX STRATEGY SHOULD BE STRUCTURED,
DEFENSIBLE & TRULY ALIGNED WITH YOUR BUSINESS GOALS.
An international tax attorney often becomes relevant before a taxpayer thinks of the matter as a filing problem. Changes in ownership, residence, financing, distributions, entity structure, or where income is earned can create U.S. tax consequences even when the underlying business activity occurs abroad.
International tax planning should identify who owns an entity, who receives a payment, where the parties reside, and how the transaction is characterized. A cross-border tax attorney can use those facts to determine which U.S. rules need further analysis before documents or cash flows are finalized.
A foreign income tax attorney may need to separate income-source questions from residency and reporting obligations. Those issues can interact, but they are not identical. An international tax law firm can coordinate the U.S. analysis while foreign counsel addresses local-law consequences in another jurisdiction.
Once ownership changes, money moves, or a taxpayer changes residence, some planning alternatives may disappear. Early review gives the legal team time to compare the expected U.S. tax result with the commercial objective and the reporting that will follow.
Unreported foreign income requires a different analysis from prospective planning. The first task is to understand what was omitted, for which years, and what related forms or accounts may be involved. The response should not assume that one correction method fits every taxpayer.
Clients searching for an international tax attorney Houston can use this page for cross-border strategy and legal analysis. Reporting-focused matters may move to Tax Compliance, while disputes can move to Tax Controversy. That division keeps each issue with the practice that best matches the immediate legal need.
