Tax Expert Today LLC handles international tax matters from Naples, Florida, for clients across the United States and abroad. This page covers foreign income reporting, FBAR and FinCEN Form 114, Form 8938 and FATCA, the Streamlined Filing Compliance Procedures, Form 5471, and foreign tax credit planning.
To be clear about location, because search engines frequently confuse the two: this office is in Naples, Florida, in Collier County, in the United States. It is not Naples, Italy. Clients are served in Naples, Bonita Springs, Estero, Fort Myers, Marco Island, and throughout Southwest Florida, as well as nationwide and overseas. Clients who also need domestic planning alongside the cross-border work can review the firm broader tax services in Naples.
International Tax Naples FL: What We Handle
International tax work in Naples FL covers foreign bank account reporting, foreign asset disclosure, unfiled returns for Americans living abroad, foreign corporation and partnership filings, and credit or exclusion planning that keeps the same income from being taxed twice. Most engagements begin with a compliance review of the last six years.
The specific filings handled most often are these.
- FinCEN Form 114, the FBAR. Required reporting of foreign financial accounts.
- Form 8938. Statement of Specified Foreign Financial Assets under FATCA, filed with the income tax return.
- Streamlined Filing Compliance Procedures. The remaining path to correct non willful failures to report foreign income and accounts.
- Form 5471. Information return for United States persons with interests in foreign corporations.
- Form 8865 and Form 8858. Foreign partnership and foreign disregarded entity reporting.
- Form 2555 and Form 1116. Foreign earned income exclusion and foreign tax credit planning.
- Form 3520 and Form 3520-A. Foreign trust and large foreign gift reporting.
- Expatriate and dual status returns for taxpayers arriving in or departing from the United States.
Who Typically Needs International Tax Help in Naples
Southwest Florida has an unusually international population for a market its size, and the reporting profiles differ sharply. The answer that fits a retiree with one European account is not the answer that fits an owner of a foreign operating company. Four situations come up repeatedly.
Retirees and seasonal residents with accounts abroad. A pension, a bank account left open in a home country, or an inherited account can create an annual FBAR obligation even when no money moves and no income is earned. Many taxpayers in this group have filed United States returns faithfully for decades and have simply never been told the account was reportable.
Dual citizens and green card holders. United States tax obligations follow citizenship and residency status, not physical location. A dual citizen who has lived abroad their entire adult life is still required to file, and frequently discovers this only when a foreign bank asks for FATCA documentation.
Business owners with foreign operations or entities. Signature authority on a subsidiary account, an interest in a family company overseas, or a foreign entity formed to hold property can each trigger separate annual filings with penalties that begin in the five figures.
New arrivals and departures. Taxpayers moving into or out of the United States face dual status years, treaty positions, and in some cases expatriation reporting. These years are the most error prone in international practice because two different sets of rules apply to the same twelve months.
Looking for a Foreign Tax CPA in Naples, Florida?
Many people search for a foreign tax CPA in Naples when what they actually need is a firm authorized to represent them before the IRS on international matters. Tax Expert Today LLC is a multidisciplinary firm. The firm includes CPAs and attorneys working alongside enrolled agents, and the founder is an enrolled agent, which is the credential that carries unlimited practice rights before the IRS.
That distinction matters on international cases. Enrolled agents, CPAs, and attorneys all hold unlimited representation rights under Circular 230. For an unfiled FBAR or a Streamlined submission, what determines the outcome is experience with the specific procedure and the ability to represent you if the IRS questions the filing, not which of the three credentials appears on the letterhead.
FBAR and FinCEN Form 114 Filing
An FBAR is required if you are a United States person and the combined highest balances of your foreign financial accounts exceeded 10,000 dollars at any point during the calendar year. The threshold is aggregate, not per account, and it is measured at the highest balance, not the year end balance.
Signature authority alone can trigger the requirement even where you own nothing in the account. That catches Naples business owners who sign on a foreign subsidiary account and retirees who remain signatories on a parent’s or an adult child’s overseas account. FinCEN Notice FIN-2025-NTC3 continues to defer the filing deadline for certain officers and employees with signature authority only, currently to April 15, 2027. That deferral is narrow and applies to a defined category of filers, so it should be confirmed against your specific facts rather than assumed.
Form 8938 and FATCA Reporting
Form 8938 is separate from the FBAR and is filed with your income tax return rather than with FinCEN. The thresholds are higher, they vary by filing status, and they vary again depending on whether you live inside or outside the United States. Filing one form does not satisfy the other, and many taxpayers owe both.
The two regimes cover overlapping but different assets. Foreign stock held directly, foreign partnership interests, and foreign issued life insurance with cash value are reportable on Form 8938 but are not foreign financial accounts for FBAR purposes. Foreign real estate held directly is reportable on neither, though an entity holding that real estate may itself be reportable.
Streamlined Filing Compliance Procedures
The Streamlined Filing Compliance Procedures remain open and are the primary route for taxpayers whose failure to report foreign income and accounts was non willful. A submission requires three years of amended or delinquent income tax returns, six years of FBARs, and a signed certification explaining the non willful conduct. Separate versions of the procedure apply to taxpayers residing inside and outside the United States, and the penalty terms differ between them.
An important change to note, because a great deal of published guidance is now out of date: the Delinquent FBAR Submission Procedures were eliminated effective July 1, 2026. Pages and articles that still present the delinquent procedures as an available option are describing a program that no longer exists. Taxpayers who would previously have used that route need a different analysis, and in many cases the reasonable cause position now has to be made directly rather than through a named program.
The certification is the part of a Streamlined submission that most often causes problems. It is signed under penalty of perjury, and it is the document the IRS reads first if the submission is later examined. It should be drafted with the same care as a response to a notice, not filled in as a formality.
Form 5471 and Foreign Corporations
United States persons who are officers, directors, or shareholders of a foreign corporation may owe Form 5471 regardless of whether the corporation distributed anything. The categories of filer differ substantially in what they require, and the penalty for a late or incomplete return begins at 10,000 dollars per form per year.
Naples sees this frequently with clients who hold an interest in a family company abroad, or who formed a foreign entity for a property purchase without realizing it created an annual United States filing obligation. The filing is informational, so there is often no tax due at all, which is precisely why it goes unnoticed until penalties have accumulated across several years.
Foreign Tax Credit and Double Taxation Planning
The United States taxes citizens and residents on worldwide income regardless of where they live. Relief from double taxation comes through the foreign earned income exclusion on Form 2555, the foreign tax credit on Form 1116, or an applicable treaty position. These interact, and choosing one can foreclose another.
Electing the foreign earned income exclusion and later revoking it, for example, generally bars you from re-electing for five years without IRS consent. That is the kind of decision worth modeling before it is made rather than discovering afterward. For taxpayers in higher tax jurisdictions, the credit frequently produces a better long run result than the exclusion, but the comparison depends on income type, local rates, and whether the taxpayer expects to return to the United States.
What an International Compliance Review Covers
An international compliance review establishes what is actually required before anything is filed. It looks at the last six years of returns and foreign account activity, identifies which forms were owed and which were missed, and determines which correction procedure the facts support. Filing before that analysis is the most common and most costly mistake.
The review typically works through account inventory and highest balances by year, entity interests and signature authority, income actually earned on foreign assets, previously filed returns and any prior disclosures, and the resulting exposure under each available path. Only then does it make sense to choose between a Streamlined submission, a reasonable cause position, or simple prospective compliance.
Order matters more than speed here. Submitting individual years piecemeal can foreclose a procedure that would otherwise have been available, and once a return is filed the framing of the earlier failure is much harder to change.
Penalties for Missed International Filings
International information return penalties are among the steepest in the Internal Revenue Code, and most of them apply regardless of whether any tax was owed. Non willful FBAR penalties are assessed per report, and willful penalties can reach the greater of a fixed statutory amount or half the account balance. Form 5471, Form 8865, and Form 3520 each carry penalties beginning at 10,000 dollars per form per year.
Two features make these worse than ordinary penalties. Several international information return penalties are assessed without the deficiency procedures that normally give a taxpayer a path to Tax Court before payment, and the statute of limitations on the entire return can remain open where required international forms were never filed. A missing Form 5471 can therefore keep an otherwise closed year open indefinitely.
Naples and Southwest Florida International Tax Help
International tax help in Naples and Southwest Florida is available in person at the North Naples office or remotely for clients elsewhere in Florida, in other states, and overseas. Consultations begin with a review of your filing history and foreign account position to establish what is actually required before anything is filed.
To discuss an international tax matter, call (239) 441-2005 or request a consultation. The office is at 11983 Tamiami Trail N, Naples, FL 34110.
Frequently Asked Questions
Do I need to file an FBAR if my foreign accounts are small?
The test is the aggregate highest balance of all foreign financial accounts during the year, not the balance of any single account and not the year end balance. If the combined highest balances exceeded 10,000 dollars at any point, the FBAR is required even though each individual account is modest.
Are the Delinquent FBAR Submission Procedures still available?
No. The Delinquent FBAR Submission Procedures were eliminated effective July 1, 2026. The Streamlined Filing Compliance Procedures remain open for taxpayers whose conduct was non willful. Anyone relying on guidance that still lists the delinquent procedures should have their situation reassessed.
Do I have to file both the FBAR and Form 8938?
Frequently, yes. They are separate requirements with different thresholds, different filing destinations, and partly different covered assets. Filing one does not satisfy the other, and it is common for a taxpayer to owe both for the same year.
I live abroad and have not filed for years. Where do I start?
Start with a compliance review rather than with filing. The order in which returns, FBARs, and any certification are submitted affects both the penalty exposure and which procedure you qualify for. Filing individual years piecemeal before that analysis can foreclose the better option.
Can a missed foreign form keep an old tax year open?
Yes. Where a required international information return was never filed, the limitations period on the entire return can remain open rather than closing on the normal schedule. This is one reason unfiled foreign forms are worth addressing even for years a taxpayer assumes are long settled.
Does the firm serve clients outside Naples, Florida?
Yes. The firm is based in Naples, Florida, in Collier County, and serves clients in all 50 states and abroad. Remote engagements are routine for international matters, since the work is document driven rather than location dependent.
This page is general information, not advice for a specific taxpayer. International reporting obligations depend on facts that vary case by case. Fees are scoped after consultation.