LTB

Tax Advisory

Our tax authority already knew about the foreign account.

Under the Common Reporting Standard, and FATCA for US persons, financial institutions identify the tax residence of account holders and controlling persons and report balances, income, and proceeds to their own authority, which exchanges the data automatically with the account holder's country of residence each year. Nothing is requested from the taxpayer, and nothing signals that it has happened.

Mismatches, not evasion, drive most enquiries. A self-certification given years ago names a residence the client has since left. A company account is reported with the wrong controlling person. A passive entity is reported as active, or the reverse. The same account is reported by two institutions on different bases. The authority receives a figure that does not reconcile to the return, and an audit notice follows, often about a structure that is entirely lawful.

The scope keeps widening. Crypto exchanges and certain payment institutions now report on comparable terms, so an account opened outside the traditional banking system is not outside the exchange.

How LTB Resolves It

LTB reconstructs what has most likely been reported and by whom, reviews every self-certification and controlling-person declaration on file against the client's actual residence and structure, and identifies where the reported picture and the filed position diverge.

Corrected self-certifications go to the institutions, and amended returns or voluntary disclosures are prepared and filed by the licensed tax professionals in LTB's network in the relevant jurisdiction. Where the underlying structure is what produces the mismatch, LTB restructures it so future exchanges report the position the client is actually taking, and coordinates responses to any enquiry as a single engagement.

Questions

Frequently Asked

The institution's self-certification can be corrected going forward, and prior periods addressed by amended return or voluntary disclosure. Timing matters: a correction made before an enquiry is treated very differently from one made after.

No legitimate structure does. Controlling persons of passive entities are reportable, and presenting the position accurately is what prevents the mismatch that triggers an audit.

Begin With a Confidential Conversation

Whether you were referred to LTB or found the practice directly, the first conversation is confidential and without obligation.

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