Multinationals, Foreign Whistleblowers, and Related Concerns

The Ferraro Law Firm
Washington, D.C. — Miami, Florida

The age of globalization has made the process of assessing and collecting taxes from businesses increasingly difficult for governments everywhere. In many cases, governments must rely on business taxpayers having a sense of honesty and fair play with regard to paying their taxes. Unfortunately, corporations with headquarters across the globe and subsidiary companies everywhere seem more interested in playing a shell game with their profits rather than playing fair with IRS income reporting requirements.

You do not need to be a U.S. citizen in order to be eligible for an award from the IRS.

For assistance with putting your claim together the right way and reporting tax underpayment information to the right people, contact our tax lawyers today in Washington, D.C. or Miami, Florida.

The most important thing foreign individuals should know about the IRS's Whistleblower Rewards program is that anyone who makes a "substantial contribution" of information about a tax underpayment is eligible to receive an award from the U.S. government. The Ferraro Law Firm attorneys have years of experience in international tax law, and are familiar with the methods by which foreign and U.S. companies and individuals shelter their income from US taxation.

Foreigners working in overseas headquarters are ideally placed to identify large-scale U.S. tax underpayments by their company or its U.S. subsidiaries. In addition, foreigners working for a U.S. company with an international presence are also in a great place to discover information about how the foreign subsidiary is being used to underpay the company's consolidated tax liability in the United States.

Furthermore, the question of whether a foreign whistleblower is subject to US tax on their award is currently unsettled.  The IRS announced in PTMA 2012 that they withheld an award paid to foreigners in some circumstances, but it is not clear yet whether that means you may be liable for US taxes.  We can help guide you through this process and take steps to best insure you do not take actions that will surely make your award subject to US tax.

In any case, discussing your information with a lawyer prior to providing information to the IRS can yield valuable benefits.