Tax Attorneys: Offshore & Voluntary Disclosure Specialist

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 SpecialistOur international tax lawyer team at Golding & Golding has helped thousands of taxpayers successfully navigate the complex maze of FBAR & FATCAOur Tax Attorney & Enrolled Agent team represents clients nationwide and worldwide.

Board-Certified Tax Attorney

Becoming a Board-Certified Tax Specialist is a tough feat. There are more than 200,000 attorneys in California alone, and tens of thousands of them practice in some area of tax, including tax litigation, employment tax, real estate tax, & IRS Offshore Disclosure. Sean M. Golding is one of less than 350 Attorneys (out of more than 200,000 practicing California Attorneys) to earn the Certified Tax Law Specialist credential. The credential is awarded to less than 1% of Attorneys nationwide.

Flat-Fee, Full-Service (Tax & Legal)

Our Offshore Tax Attorney team offers flat-fee, full-service representation for tax preparation, legal representation and IRS tax audit/examination defense.  We are the "go-to" international tax lawyers for clients, CPAs, Lawyers, Financial Planners, and businesses across the globe. Our EA and Offshore Voluntary Disclosure Lawyer team handles the entire tax, legal, & examination defense process, from beginning-to-end. Avoid less-experienced firms trying to mislead you.

International Tax Compliance: FBAR & FATCA

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. We have helped thousands of clients get domestic & offshore compliant.

IRS Voluntary Disclosure Program (VDP)

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

Streamlined Domestic Offshore (SDOP)

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 offshore penalty. The purpose of the Streamlined Domestic Offshore Program is to leverage a smaller penalty now, against a potentially larger penalty later, and certify non-willfulness.

Streamlined Foreign Offshore (SFOP)

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. It allows individuals to come into IRS Tax and Reporting Compliance, without having to pay any penalties. In addition, a person can file late original returns for prior years.

Delinquent Information Returns (DIIRSP)

Delinquent International Information Return Submission Procedures: If you have not filed one or more required international information returns, such as a 5471, 3520-A, or 8865, the IRS may penalize you extensively for not being in "IRS Offshore Compliance." DIIRSP is designed to help safely bring people into compliance with a reduced risk of an "offshore penalty." Common IRS International Informational Returns: FBAR, FATCA, 3520, 5471, 5472, 8938, 8865 & 8621.

Offshore Reasonable Cause 

A Reasonable Cause submission letter for FBAR, FATCA and international tax in general is a very complex and delicate undertaking, There is no "form" for the submission, and you need to rely on the experience of your Tax Attorney. Each person's facts and circumstances are different, and reasonable cause is evaluated differently depending on who is reviewing the reasonable cause statement at the IRS.  We have successfully represented 100s of clients with Reasonable Cause.

Reduce & Avoid IRS Offshore Reporting Penalties

FBAR Penalties

FBAR penalties can range extensively. The main categories include: Civil Penalties and Criminal Penalties. Civil FBAR Penalties can be broken down further into Willful and Non-Willful. Non-Willful Penalties can go as high as $10,000 per account, per year. Willful Penalties can reach 50% penalty on the maximum value of the account(s). We help people reduce, minimize, & avoid these penalties.

FATCA Penalties

A person may be subject to a FATCA penalty of $10,000. And, if you do not file a correct and complete Form 8938 within 90 days after the IRS mails you a notice of the failure to file, you may be subject to an additional penalty of $10,000 for each 30-day period (or part of a period) during which you continue to fail to file Form 8938 after the 90-day period has expired, up to $50,000.

Form 3520 Penalties

The initial Form 3520 penalty is equal to the greater of $10,000 or: 35% of the gross value of any property transferred to a foreign trust; 35% of the gross value of the distributions received from a foreign trust; 5% of the gross value of the portion of the foreign trust's assets treated as owned by a U.S. person under the grantor trust rules, and potential additional separate penalties as well.

Form 5471 Penalties

A $10,000 Form 5471 penalty is imposed for each annual accounting period of each foreign corporation for failure to furnish the information required by section 6038(a) within the time prescribed. If the information is not filed within 90 days after the IRS has mailed a notice of the failure to the U.S. person, an additional $10,000 penalty (per foreign corporation) is charged up $50K per failure.

Form 5472 Penalties

A Form 5472 penalty of $25,000 will be assessed on any reporting corporation that fails to file Form 5472 when due. Each member of a group of corporations filing a consolidated information return is a separate reporting corporation subject to a separate $25,000 penalty, If the failure continues for +90 days after notification by IRS, an additional penalty of $25,000 will apply.

Form 8621 Penalties

Form 8621 is a form that is required to be filed by individuals who have a PFIC (Passive Foreign Investment Company) and are not exempt from filing. If you are required to report a form 8621 but failed to do so, that means your tax return is incomplete and the IRS can go back and audit you for years to come, on that return (aka the Statute of Limitations does not expire). This may lead to additional penalties.

Form 8865 Penalties

A $10,000 Form 8865 penalty is imposed for each tax year of each foreign partnership for failure to furnish the required information within the time prescribed. If the information is not filed within 90 days after the IRS has mailed a notice of the failure to the U.S. person, an additional $10,000 penalty (per foreign partnership) up to a maximum of $50,000 for each failure. Additional penalties may apply.

Form 8938 Penalties

A person may be subject to a Form 8938 penalty of $10,000. And, if you do not file a correct and complete Form 8938 within 90 days after the IRS mails you a notice of the failure to file, you may be subject to an additional penalty of $10,000 for each 30-day period (or part of a period) during which you continue to fail to file Form 8938 after the 90-day period has expired, up to $50,000.

Offshore Tax Fraud Penalties

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.


We Specialize in IRS Offshore Voluntary Disclosure
Sean M. Golding - JD, LL.M., EA

International & Offshore Tax Lawyer

Our Managing Partner, Sean M. Golding, is a 20-year attorney with a license in both New York & California and has a Master's degree in Tax Law from University of Denver (where he also completed his undergraduate degree).


Sean M. Golding is one of less than 350 attorneys (out of more than 200,000 practicing California Attorneys) to earn the Board-Certified Tax Law Specialist credential. (Earned by less than 1% of attorneys nationwide). Sean has also earned the prestigious IRS Enrolled Agent credential. He represents clients before the IRS nationwide and worldwide in over 75 countries.

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

International & Offshore Tax Lawyer

Jenny has been living in Southern California for over 30 years. She earned a Bachelor of Arts in Business Economics and then graduated from USC Gould School of Law (a Top 20 Law School). Jenny has over 15 years of legal experience and works directly with Sean on various complex tax and estate planning matters.


Having grown up helping her immigrant parents forge their way in America, she fully understands how confusing and overwhelming the American legal system can be. Thus, she truly enjoys assisting clients with diverse backgrounds and cultures and helping them with their legal issues. 

International Tax Blog  

IRS Offshore Disclosure Testimonials  

“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
“The Only Lawyer I don’t have to Babysit – His Confidence, Expertise, and Experience are Truly Reassuring…Lastly, Sean cares for his clients. I can not stress how rare it is to find an attorney who genuinely cares.” – Reasonable Cause Client
“Mr. Golding was prompt, professional, reassuring (and explained everything patiently and thoroughly) and very attentive. I was not aware about a filing requirement for several years, and he handled the process for me. He was always a pleasure to deal with, and he is as kind as he is skilled.” – FATCA & FBAR Disclosure Client.
“Sean closely examined my situation and he educated me of various options available for me. He was very patient and answered all my questions on timely manner. After consulting him I felt relaxed. Sean and his firm were very supportive in the entire process to safely report my offshore accounts to the treasury. Overall I am very satisfied with the outcome.” – Streamlined Disclosure Client