Brotman Law — high net worth tax attorney

For High-Net-Worth Individuals

High Net Worth Tax Attorney
Protect Your Wealth. Legally.

International tax compliance, offshore account disclosure, FBAR defense, asset protection, and proactive tax strategy for individuals with complex financial profiles.

Sam BrotmanSam Brotman, J.D., LL.M.|Last updated April 2026

Key Takeaway

A high-net-worth tax attorney is a lawyer who handles complex tax matters including offshore account compliance (FBAR/FATCA), international tax structuring, estate and gift tax planning, and IRS wealth squad audits. Taxpayers with assets exceeding $10 million face IRS audit rates of 8-12%, significantly higher than the general population. Call Brotman Law at (619) 378-3138 for a free intro call about protecting your wealth from aggressive IRS enforcement.

High Net Worth Means High Tax Exposure.

The IRS dedicates specialized resources to auditing high-income and high-net-worth taxpayers. In 2025, the IRS announced significantly increased audit rates for individuals with income above $1 million — and those numbers continue to climb. If your financial picture includes international investments, offshore accounts, real estate portfolios, or complex business structures, you're operating in the IRS's highest-priority enforcement zone.

The penalties for international tax noncompliance are staggering. A single missed FBAR filing can result in penalties of $10,000 per account per year for non-willful violations — or the greater of $100,000 or 50% of the account balance for willful violations. FATCA penalties add another layer. And these penalties are assessed per form, per year, meaning they compound rapidly.

We serve high-net-worth individuals who need both proactive tax planning and, when necessary, aggressive defense against IRS enforcement. Our attorneys handle international tax compliance, voluntary disclosure programs, offshore account remediation, and audit defense for clients with complex financial situations.

Whether you need to get compliant, defend against an audit, or build a tax-efficient structure for your wealth, we bring the specialized expertise these situations demand.

How We Help High-Net-Worth Clients

Specialized Tax Services for Complex Wealth

International Tax Compliance

FBAR filings, FATCA reporting, foreign trust returns (Forms 3520/3520-A), Form 5471 for foreign corporations, and Form 8865 for foreign partnerships. We ensure full compliance with every international reporting obligation.

Offshore Account Disclosure

If you have unreported foreign accounts, the risk of criminal prosecution is real. We guide clients through voluntary disclosure programs, streamlined filing procedures, and delinquent FBAR submissions to get compliant while minimizing penalties.

FBAR Defense

Facing FBAR penalties or an IRS examination of your foreign accounts? We defend against both willful and non-willful penalty assessments, negotiate reductions, and challenge improper characterizations of your reporting history.

Estate & Gift Tax Planning

Strategic estate planning that minimizes transfer taxes while preserving your wealth for future generations. Grantor trusts, family limited partnerships, charitable structures, and lifetime gifting strategies — all designed to reduce your taxable estate.

Asset Protection

Domestic and international asset protection structures that shield your wealth from creditors, litigation, and excessive tax exposure. We design holding structures, trusts, and entity frameworks that create legally defensible barriers.

IRS Audit Defense

High-income audits are handled by specialized IRS examiners with more experience and more time than standard audits. We represent clients through IRS examinations, appeals, and Tax Court when necessary.

Trusted by High-Net-Worth Clients

The Experience Complex Situations Demand

$500M+

In Tax Debt Resolved

150+

Multimillion-Dollar Transactions

20+

Years Serving HNW Clients

See our case results and client testimonials

Key Risk Areas

Where High-Net-Worth Individuals Face the Greatest Tax Exposure

The IRS prioritizes these areas for audit and enforcement. If any apply to you, proactive planning is essential.

Unreported Foreign Financial Accounts

The IRS receives foreign account data from over 100 countries through automatic exchange agreements. If you have accounts exceeding $10,000 in aggregate value and haven't filed FBARs, the IRS likely already knows. Voluntary disclosure before detection is always the better outcome. Read our International Tax Guide for more detail.

Cryptocurrency Holdings

The IRS has made cryptocurrency tax enforcement a top priority. Centralized exchanges report to the IRS, and blockchain analytics tools allow the agency to trace transactions on decentralized platforms. If your crypto portfolio is substantial, proper reporting and tax planning are critical.

California Residency Disputes

California's top income tax rate of 13.3% makes the state aggressive about claiming residents. If you've moved out of California — or split time between California and another state — the FTB may audit your residency. We handle residency disputes and help clients make clean breaks.

Complex Business Exits

Selling a business, taking a company public, or executing a merger creates enormous tax consequences. Exit planning done correctly can save millions in taxes. Done poorly — or not at all — and the tax bill can be devastating. QSBS, installment sales, opportunity zone deferrals, and charitable strategies all require advance planning.

Real Estate Portfolio Tax Exposure

Large real estate portfolios create complex tax situations involving depreciation recapture, 1031 exchanges, passive activity rules, and state nexus issues. We design tax-efficient structures for real estate investors and defend against IRS challenges to exchange transactions and property valuations.

Client Testimonials

Trusted by Discerning Clients

Results that reflect the caliber of representation our clients expect.

★★★★★

"I had unreported foreign accounts going back years and was terrified of the penalties. Sam's team got me into the streamlined program and the penalties were a fraction of what I feared. More importantly, I can sleep at night now."
Offshore Accounts Resolved HNW Individual, La Jolla, CA

★★★★★

"When we sold our company, Brotman Law's exit planning saved us over $2 million in taxes through QSBS and installment sale structuring. Our previous advisors never even mentioned these strategies."
$2M+ Tax Savings on Exit Tech Founder, San Diego, CA

★★★★★

"The FTB was trying to claim I was still a California resident two years after I moved. Sam's team built an airtight case documenting my domicile change. The FTB backed down completely."
Residency Audit Dismissed Former CA Resident, Austin, TX
Super Lawyers Inc. 5000

Why Brotman Law

The Right Counsel for Complex Wealth

International Tax Depth

We handle FBAR, FATCA, foreign trusts, and cross-border transactions daily — not as a sideline, but as a core practice area.

Absolute Confidentiality

Attorney-client privilege protects every conversation from day one. Your financial situation stays between you and your attorney.

Defense-Informed Planning

Having defended hundreds of audits, we design strategies that withstand IRS scrutiny — because we know exactly what the IRS looks for.

Proactive, Not Reactive

We identify and address tax risks before they become enforcement actions. Annual tax planning reviews keep your strategy current as laws change.

Multi-Disciplinary Approach

Tax law, business law, estate planning, and asset protection — all under one roof. No referrals, no delays, no gaps in strategy.

Discreet & Professional

We understand the sensitivity of high-net-worth tax matters. Our practice is built on discretion, precision, and personalized service.

Case Study

$1.4M Potential FBAR Penalties Reduced to $21,000 Miscellaneous Offshore Penalty

A dual US-UK citizen living in California discovered she had not been filing Reports of Foreign Bank and Financial Accounts (FBARs) on three bank accounts held in the United Kingdom. The accounts — a current account, a savings account, and an ISA (Individual Savings Account) — had a combined balance of approximately $2.1 million and had been maintained since before she became a US person. She had been filing US tax returns each year but had no idea that foreign account reporting obligations existed separately from income tax filing. The potential penalty exposure was staggering: the IRS can assess penalties of up to $100,000 or 50% of the account balance per violation for willful FBAR failures. Even under the non-willful penalty structure, theoretical exposure exceeded $70,000 per account per year — over $1.4 million across seven years and three accounts. Criminal referral was also a possibility. We determined she was an excellent candidate for the IRS Streamlined Filing Compliance Procedures designed for non-willful taxpayers. We prepared a detailed non-willfulness certification documenting that she had relied on a UK-based accountant who was unfamiliar with US reporting requirements, that the accounts were opened and maintained for ordinary banking purposes, that no income was hidden or diverted, and that all interest and dividend income had been reported on her US returns. We filed seven years of amended federal returns (Forms 1040-X), seven years of delinquent FBARs (FinCEN 114), and the required certification statement.

The IRS accepted the Streamlined submission. The total penalty was a single 5% Miscellaneous Offshore Penalty of $21,000 — applied to the highest aggregate balance in one year — eliminating over $1.4 million in potential penalties and any risk of criminal prosecution.

Details have been changed to protect client confidentiality. Prior results do not guarantee a similar outcome.

Frequently Asked Questions

High Net Worth Tax FAQs

What are the penalties for not filing an FBAR?+

Non-willful FBAR penalties can reach $10,000 per account per year. Willful violations carry penalties of the greater of $100,000 or 50% of the account balance — per account, per year. With multiple accounts and multiple years, penalties can exceed the total account value. Criminal prosecution is also possible for willful violations. Early voluntary disclosure dramatically reduces exposure.

I have unreported offshore accounts. What should I do?+

Contact a tax attorney immediately — before doing anything else. Do not file amended returns or delinquent FBARs without legal guidance. Depending on your circumstances, the streamlined filing compliance procedures, delinquent FBAR submission procedures, or a voluntary disclosure may be the best path. Each has different penalty structures and different risk profiles. We assess your situation and recommend the approach that minimizes both penalties and criminal exposure.

How likely am I to be audited as a high-income individual?+

Significantly more likely than average. The IRS has publicly stated that audit rates for taxpayers earning over $1 million will increase substantially, with the goal of reaching audit rates not seen since 2010. International information returns, large deductions, complex entity structures, and cryptocurrency transactions all increase audit probability further.

Can you help me move out of California tax-efficiently?+

Yes. We help high-net-worth individuals establish domicile in other states while minimizing California's ability to claim continued residency. This involves documenting your departure across multiple factors — driver's license, voter registration, professional licenses, time tracking, and social ties. Read our California Residency Guide for a detailed overview of the process.

Do I need a tax attorney or a wealth manager?+

You need both, but they serve different roles. Wealth managers handle investment allocation and financial planning. Tax attorneys handle legal structuring, compliance, IRS defense, and strategies that require legal implementation — entity formation, trust creation, voluntary disclosures, and audit representation. We coordinate with your wealth management team to ensure tax strategy and investment strategy are aligned.

What does a high-net-worth tax engagement cost?+

Fees vary based on complexity, but our clients consistently find that the tax savings and penalty avoidance far exceed the cost of representation. For proactive planning engagements, we typically see a 5-10x return on investment in the first year. For defense matters, the comparison is between our fees and the penalties and tax liability we reduce or eliminate. We provide clear fee estimates before any engagement begins.

As Featured In & Recognized By
Super Lawyers The Wall Street Journal The New York Times Reuters Inc. 5000 Forbes Business Council

Get Started Today

Book Your Free 15-Minute Call

Schedule a brief call with our team to discuss your situation. We'll assess where things stand and outline your options — confidentially and without obligation.

  • Completely confidential — protected by attorney-client privilege
  • Every situation is different — you'll receive a custom assessment tailored to yours
  • Same-day and next-day appointments available
Book Your Free 15-Minute Call or call us directly (619) 378-3138