Who are Golding & Golding?

Our Offshore Tax Attorneys specialize exclusively in IRS Offshore & Streamlined Voluntary Disclosure of domestic & foreign accounts, assets, investments and income. Each case is led by a  Board-Certified Tax Attorney Specialist with 20+ years legal experience. Our international tax attorney team at Golding & Golding has helped thousands of taxpayers successfully navigate the complex maze of FBAR & FATCA. Our International Tax Attorney team represents clients nationwide and across the globe, with tax preparation, legal representation, IRS follow-up, and examination defense. 

*Beware of less-experienced copycat law and tax firms trying to mislead you about offshore disclosure.

What is IRS Offshore Disclosure?

IRS Offshore Disclosure is the process for U.S. Taxpayers to disclose previously unreported foreign accounts, assets, income, & investments. The main programs are: Traditional Voluntary Disclosure Program; Streamlined Filing Compliance Procedures; Delinquent International Informational Return Submission Procedures, and Reasonable Cause. Our Tax Attorneys have helped 1000s of clients get compliant and avoid a high-stakes FBAR & offshore catastrophe.

IRS Voluntary Disclosure Program (New OVDP)

IRS Voluntary Disclosure Program: VDP is the oldest offshore voluntary compliance program. In recent years, the IRS has developed several offshore voluntary disclosure tax amnesty compliance programs to allow Taxpayers to report and disclose unreported assets & income. Under the new version of the program, the IRS combined Offshore and Domestic Voluntary Disclosure into one program. Our Tax Attorneys can help you get compliant.

Streamlined Domestic Offshore Procedures

Streamlined Domestic Offshore Procedures: When U.S. resident Taxpayers have unreported offshore assets, income, accounts & assets and are non-willful, they may qualify for SDOP, and a reduced a 5% Title 26 miscellaneous offshore penalty. Our Tax Lawyers represent clients in the Streamlined Domestic Offshore Program in order to leverage a smaller penalty now, against a potentially larger penalty later. This reduces the chance of a tax audit or examination in the future.

Streamlined Foreign Offshore Procedures

The Streamlined Foreign Offshore Procedures or (SFOP) is a great program for expats and other individuals who do not qualify as a U.S. citizen or legal permanent resident. it a highly cost-effective method of quickly getting you into IRS (Internal Revenue Service) or DOT (Department of Treasury) compliance. Our Tax Attorneys represent you with getting into IRS Tax and Reporting Compliance, without having to pay any penalties. It also allows taxpayers to file original tax returns.

Delinquent International Information Returns

Delinquent International Information Return Submission Procedures: If you have not filed one or more required international information returns, such as a 5471, 3520, or 8938, or the FBAR the IRS may penalize you extensively for not being in “IRS Offshore Compliance.” Our Tax Lawyers are very experienced with DIIRSP. The program is designed to help safely bring people into compliance with a reduced risk of an “offshore information return penalty.”

Delinquent FBAR Submission Procedures

Delinquent FBAR Submission Procedures: If you are only out of compliance for not filing the annual FBAR (FinCEN Form 114), and you do not have any unreported income, you may be able to avoid FBAR Penalties. Our Tax Lawyers are very experienced with the Delinquent FBAR Submission Procedures. This program is also designed to help safely bring U.S. taxpayers from around the world into compliance with a reduced risk of an “offshore penalty.” These penalties can be civil or criminal.

Offshore Penalty Abatement

When a person is liable for international tax fraud or tax evasion, they may be subject to either civil and or criminal tax fraud and evasion penalties. These IRS offshore penalties may result in significant monetary penalties, and penalties on taxes due. In addition, the matter may be referred to an IRS Special Agent investigation, which may lead to prosecution, more financial penalties, & prison. Our Offshore Tax Attorneys can help.

Covered Expatriates & Exit Tax

Expatriation is the process of relinquishing U.S. Citizenship or Legal Permanent Resident Status (Depending on if the filer is a Long-Term Resident). Some expatriates that are considered covered expatriates will have to prepare a shadow sale of their assets using a Mark-to-Market election on Form 8854, and possibly pay an Exit Tax. Our Expat Tax Attorneys can help with offshore disclosure and expatriation.

International Tax Blog – Golding & Golding

India Offshore Compliance for U.S. Tax & Reporting
?   India Offshore Compliance & the IRS India Offshore Tax & Reporting Compliance: The India offshore tax and reporting compliance rules are very complex. In recent years, the IRS has increased the enforcement of foreign accounts compliance and unreported offshore income. Due to nature and […]
FBAR Penalties & IRS FBAR Penalty Enforcement
  FBAR Penalties & the IRS FBAR Penalties: The issuance of FBAR Penalties are on the rise. FBAR is a shorthand way of referring to FinCEN Form 114. FinCEN is the Financial Crimes Enforcement Network. In 2003, FinCEN authorized the IRS to enforce the FBAR Penalties […]
Attorney-Client Privilege Tax Return Preparation in Streamlined Offshore Filing
Attorney-Client Privilege Tax Return Preparation: The attorney-client privilege tax return preparation rules for IRS Streamlined Offshore are very important, in order to best protect client confidentiality. In 2014, the IRS developed the Streamlined Filing Offshore Procedures. The program was developed as an alternative to traditional voluntary […]
US. Tax Journey - Student to Visa to Green Card to Citizen
U.S. Tax Journey: The international tax lawyers at Golding & Golding have worked with thousands of clients on matters involving offshore tax and reporting compliance. While every situation is unique, and each person has their own story – oftentimes the catalyst that brings an individual foreigner into […]
Tax Court Offshore Penalty Negotiation Trials & Settlement
Tax Court Offshore Penalty Negotiation Trials & IRS Settlement: The number of Offshore Penalty tax court cases for non-filing or non-compliance with IRS International Information Return Reporting is on the rise. Tax Court can get become infinitely more complicated when the matter involves international penalties than it […]
CP15 Notice (IRS Penalty Charges for Form 3520 Gifts in 2020)
?   CP15 Notice CP15 Notice:  The CP15 Notice is an IRS Penalty Charge that requires a timely response. In a very common scenario, a U.S. Person may have recently received an IRS CP15 Notice for Form 3520 unreported foreign gifts. While the CP15 Notice may be […]

Recent Testimonials

The whole process of correcting unresolved tax issues went smoothly as Sean provided me with a courteous, timely and professional service” – Foreign Account Compliance Client

The reason went with Golding & Golding was that we wanted to work with someone that had both knowledge and expertise as well as actual in-depth experience of working through international tax situations.” – Offshore Compliance Client

Sean has provided us with an outstanding service throughout the streamlined procedure. Sean is straightforward, knowledgeable, reliable and extremely responsive. His empathic approach and ability to explain complicated matters in a simple way are very comforting in such a stressful situation.” – IRS Voluntary Disclosure Client

3 years of amended tax returns and 6 years of delinquent FBARs, plus a thoroughly researched reasonable cause statement citing the tax laws of both countries and the treaties between them. All from a jumble of papers faxed from my files. Sean had the issue resolved in less time than it took me to find out what the problem was in the first place” – Offshore Disclosure Client

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