OVDP

Offshore Voluntary Disclosure Program (OVDP): Our IRS OVDP (Offshore Voluntary Disclosure Program) Lawyers represent clients in all aspects of OVDP. Our International Tax Lawyers diligently work to protect our clients, while developing cost-effective tax and penalty reduction strategies for Foreign Income, Assets, Investments and Accounts worldwide. We represent clients in over 60 countries.

Learn the Basics of OVDP

IRS Streamlined

Streamlined Offshore Disclosure: Our International Tax Lawyers represent clients worldwide with IRS Streamlined Filing Compliance Procedures. The Streamlined Programs are designed to assist clients who are non-willful with reducing or exempting their IRS Offshore penalties for FBAR & FATCA non-compliance under approved IRS Streamlined guidelines. We Can Help!

Streamlined Domestic vs. Streamlined Foreign

Reasonable Cause

IRS Reasonable Cause Statement: Depending on the facts and circumstances surrounding your nondisclosure, our International Tax Lawyers may recommend Reasonable Cause FBAR as a viable alternative to either OVDP or the streamlined program. Reasonable cause is a fact specific submission based on each applicant's facts & circumstances, which may eliminate penalties.

Understanding Reasonable Cause

Who We Are

Golding & Golding, APLC: We are a team of International Tax Lawyers and Enrolled Agents. We focus our entire Tax Law Practice on IRS Offshore Voluntary Disclosure, including the traditional Offshore Voluntary Disclosure Program (OVDP), Streamlined Filing Compliance Procedures, FBAR Penalty Reduction, and FATCA Reporting for individuals. Mr. Golding is an International Tax Attorney licensed in both New York and California. He is also an Enrolled Agent (Highest Credential awarded by the IRS), and is authorized to represent clients worldwide.

Meet our International Tax Lawyers

We Can Help

Offshore Disclosure: We safely bring Taxpayers from around the world into IRS Tax Compliance. We work together to evaluate and analyze your case, including assessing whether you are willful or non-willful, the pros and cons of entering OVDP, Streamlined, or Reasonable Cause, and whether you may have Form 8938, 3520, 5471, 8621, PFIC or other requirements. Whether you want to fight FBAR Penalties, reduce or Avoid FATCA Penalties, or are ready to submit to OVDP or Streamlined, we can help you safely get into IRS Offshore Compliance.

Learn Your IRS Offshore Disclosure Options

What We Do

Flat-Fee, Full-Service: Our International Tax Attorneys represent hundreds of Taxpayers annually in over 50 different countries around the world in IRS Offshore Voluntary Disclosure. We have developed a unique Tax Law Firm that is devoted entirely to representing clients in IRS Offshore Voluntary Disclosure. We work with you every step of the way. Our Tax Law Offices are headquartered in a state-of-the-art facility in Irvine, California, where the staff speaks multiple languages (Chinese, Japanese, Korean, and more).

IRS Offshore Disclosure Case Accomplishments

Schedule a Reduced-Fee Initial Consultation: IRS Offshore Voluntary Disclosure Program (OVDP) Streamlined Offshore Procedures, FBAR or FATCA. We Can Help!

International Tax Blog

13Aug

Australian Superannuation is Pension or Social Security for U.S. Tax

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Australian Superannuation is Pension or Social Security for U.S. Tax We havre represented numerous clients from Australia in IRS international reporting matters. And, frequently, one of the most common questions we receive is: “What do I...

13Aug

FBAR Maximum Penalty is not $100,000, U.S. Court of Federal Claims

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FBAR Maximum Penalty is not $100,000, U.S. Court of Federal Claims — OVDP Expires Shortly They say hope springs eternal, but all the wishful thinking in the world is not going to cap your willful...

12Aug

How Do I File an FBAR – Important Key Facts About FBAR Filing

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How Do I File an FBAR – Important Key Facts About FBAR Filing The FBAR is the Report of Foreign Bank and Financial Account Form (aka FinCEN 114). Our attorneys have authored countless articles on...

10Aug

IRS Coinbase Subpoena, Taxes & Penalties – IRS Pursues Crypto “Crime”

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IRS Coinbase Subpoena, Taxes & Penalties – IRS Pursues Crypto “Crime” Recently, the IRS was awarded a subpoena to inspect documents from Coinbase — in order to uncover cryptocurrency related income. Specifically, the IRS is trying to...

Offshore Voluntary Disclosure Testimonials

“Mr. Sean M. Golding’s empathetic expertise and timely decision-making involved me in positive actions and actual solutions. My results were: no penalties, no legal issues. My own mind now rests easy, at peace.” – OVDP & International Estate Tax Client

After hiring him as our tax attorney, Sean did not disappoint. He is always positive and proactive. He basically took my hand and walked me through the complex and ever-changing FATCA and voluntary disclosure maze.” — FATCA & OVDP Client

“They did our OVDP. We got our final letter and now we have peace of mind. What a relief, thank you.” – OVDP Client with various classes of assets in numerous different countries.

“Mr. Golding, thank you for helping me get through this without any problems.” – High-Profile International Tax Law Client with 11 foreign accounts and real estate, while facing civil and criminal penalties

International Tax Law Firm Partners

Sean M. Golding, JD, LLM, EA - Certified Tax Law Specialist

IRS Offshore Voluntary Disclosure Lawyer

Sean M. Golding is one of only a handful of attorneys licensed in both New York & California and has a Master’s degree in Tax Law. He is one of less than 400 Certified Tax Law Specialists out of more than 200,000 practicing attorneys in California. Sean has nearly 20 years of legal experience and is also an Enrolled Agent, the highest credential awarded by the IRS.

Profile

International Tax Attorneys | IRS Voluntary Disclosure (OVDP), FBAR, FATCA & Streamlined Programs

Jenny Minjung Golding, Esq.

Offshore Disclosure Tax Attorney

Jenny has 11 years of legal experience and has been living in Southern California for over 30 years. After attending Whitney High School in Cerritos, Jenny earned a Bachelor of Arts in Business Economics and a Minor in Computing from UCLA. She then graduated in the top third of her class at USC Gould School of Law, which is consistently ranked as a top 20 law school.

Profile

OVDP & STREAMLINED SUCCESS!

- Reduced OVDP Penalties by 85% with an OVDP Opt-Out. We took over for another firm that was inexperienced in OVDP and got the clients into a major jam and reduced the OVDP penalty to only a fraction of the original penalty, which was LOWER than the Streamlined Penalty would have been.

- Significantly reduced an OVDP penalty by working with the IRS to evaluate a less common retirement plan, which the IRS agreed met the requirements under OVDP FAQ 55.

- Successfully Represented a Client to avoid involuntary removal from IRS OVDP when an inexperienced law firm took a client through OVDP but then tried to transition them under Streamlined Procedures, even though the client did not qualify for transition procedures due to the timing of the initial OVDP submission.

-Successfully represented a client who was represented by a firm that submitted a preclearance letter to the IRS for OVDP, even when they were completely non-willful (client unintentionally had accounts at multiple "bad banks"). Prior counsel did not understand the "Bad Bank" rules in relation to willful vs. non-willful, and was going to submit client into OVDP when it was not warranted. We were able to work with the IRS and client was approved for Streamlined Filing Compliance Procedures.

- Successfully Represented Highly Compensated Earners in a Streamlined Program Disclosure with more than 175 Accounts.

- Successfully represented a non-willful client through the Streamlined Program, even though he had multiple accounts at "Bad Banks" including accounts in a Tax Haven jurisdiction.

- Successfully received notification from the IRS of no penalties being issued against a high-income earning family with more than 20+ foreign accounts worldwide, including India and Canada. Based on their specific facts and circumstances, we were able to submit them using the Reasonable Cause option.

- Successfully completed a multi-person comprehensive disclosure matter for a family with submissions involving both Offshore Disclosure and Reasonable Cause applications.

- Secured an IRS “Notice of Completion” for a $10,000,000 Offshore Disclosure Program submission, involving over 20+ foreign accounts, foreign income, foreign assets, multiple PFICs, and other complicated foreign tax assets.

- Secured an IRS “Closing Letter” for a complex OVDP Submission involving over 15 foreign accounts, foreign retirement accounts, and foreign real estate for a client with assets in multiple countries.

- Acceptance of a Streamlined Domestic Offshore Disclosure Program submission for a client with multiple accounts, which had several U.S. Taxpayer signatories and more than $1,000,000 of funds in Costa Rica, and secured a full-penalty waiver.

- We successfully represented high-net-worth international taxpayers after their CPA fumbled an audit which left taxpayers with nearly $1,000,000 in penalties, and secured both spouses’ acceptance into the IRS Domestic Offshore Streamlined Program.

WORLDWIDE CLIENT REPRESENTATION

United States Tax Lawyers: Alabama, Alaska, Arizona, Arkansas, California, Colorado, Connecticut, Delaware, Florida, Georgia, Hawaii, Idaho, Illinois, Indiana, Iowa, Kansas, Kentucky, Louisiana, Maine, Maryland, Massachusetts, Michigan, Minnesota, Mississippi, Missouri, Montana, Nebraska, Nevada, New Hampshire, New Jersey, New Mexico, New York, North Carolina, North Dakota, Ohio, Oklahoma, Oregon, Pennsylvania, Rhode Island, South Carolina, South Dakota, Tennessee, Texas, Utah, Vermont, Virginia, Washington, West Virginia, Wisconsin, and Wyoming.

International Tax Lawyers: Afghanistan, Argentina, Australia, Austria, Bermuda, Brazil, British Virgin Islands, Bulgaria, Canada, Cayman Islands, China, Costa Rica, Germany, Hong Kong, India, Indonesia, Iraq, Israel, Italy, Japan, Jersey Islands, Korea, Malaysia, Malta, Mexico, Morocco, New Zealand, Nicaragua, Pakistan, Philippines, Singapore, Switzerland, South Africa, Thailand, Taiwan, and Turkey, and more!

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