International Tax Controversy

FBAR, Foreign Accounts, or International Tax Controversy?

Federal tax counsel for disputes involving foreign financial accounts, international information returns, penalties, offshore assets, and cross-border federal tax matters.

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Washington, D.C. Office

800 Connecticut Avenue, N.W.
Suite 300
Washington, D.C. 20006

Direct: +1 202-870-1977

Tysons Office

1750 Tysons Boulevard
Suite 1500
McLean, Virginia 22102

Direct: +1 703-403-1488

International reporting disputes can involve substantial penalties and complicated factual records. Chase Counsel evaluates the reporting history, penalty exposure, reasonable-cause and willfulness issues, and available administrative or judicial remedies.

Selected matters only. The firm does not provide routine tax-return preparation services.

Attorney Chase Sizemore, JD, LLM

Principal, Chase Counsel PLLC

Georgetown Tax LLM | Former KPMG Auditor

U.S. Tax Court | Columbia University Graduate Studies

National Institute for Trial Advocacy (NITA) Diploma

30+ Years of Legal Experience

When the stakes are high, the issue is not tax preparation. It is representation.

What We Handle

FBAR Examinations and Penalties

Disputes involving FBAR (FinCEN Form 114) examinations and assessed penalties.

Foreign Financial Account Disputes

Representation in disputes regarding foreign accounts and reporting.

Form 8938 Penalties

FATCA Form 8938 reporting disputes and penalty defense.

Forms 5471 and 5472

International corporation information return disputes and penalties.

Forms 3520 and 3520-A

Foreign trust information return matters and related penalties.

Form 8865 and International Reporting

Foreign partnership reporting and international information return penalties.

Reasonable-Cause Defenses

Reasonable-cause arguments and penalty abatement strategy.

Willfulness-Sensitive Matters

Strategy and representation in matters involving willfulness issues.

International IRS Examinations

IRS examinations involving foreign income and international transactions.

Voluntary Disclosure Issues

Evaluation and implementation of voluntary disclosure options.

Cross-Border Federal Tax Controversies

International disputes involving U.S. federal tax matters.

Before you hire a lawyer, know who you are actually hiring.

Why Clients Choose Chase Counsel

Georgetown Tax LLM | U.S. Tax Court | Former KPMG Auditor | Columbia University Graduate Studies | 30+ Years of Legal Experience

Chase Counsel is not a high-volume tax-resolution practice.

Attorney Chase Sizemore personally evaluates and leads each matter, drawing on more than thirty years of legal and advisory experience. He earned an LLM in Taxation from Georgetown University and previously worked as an auditor at KPMG. He is admitted to practice before the United States Tax Court, completed graduate studies at Columbia University, received advanced trial-advocacy training through the National Institute for Trial Advocacy, and has nearly two decades of professional experience in South Korea and China.

Outside his law practice, he founded and leads Teach Them To Fish Foundation, which builds and supports primary schools in rural Cambodia and Uganda for vulnerable children, with particular emphasis on girls' education. His humanitarian service has been recognized with the U.S. Presidential Lifetime Achievement Award, the Royal Order of Cambodia medal, and eight Cambodian Sthapana Cheat gold medals.

His published and forthcoming work includes the legal treatise Nonprofit Stewards, the memoirs The Road to Kitgum and Where the Red Earth Broke, and numerous legal and scholarly articles.

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