IRS Offshore Voluntary Disclosure Attorneys – International Tax Lawyers
Board Certified Tax Law Specialist: Our Tax Attorneys specialize in IRS Voluntary Disclosure of foreign money. IRS Offshore Voluntary Disclosure is all we do. We have represented several hundred clients nationwide & worldwide with safely getting IRS compliant. We are the Tax Lawyers that other Attorneys, CPAs ( and even IRS Personnel) contact when they have clients who want to disclose unreported income, assets, investments or accounts.
Golding & Golding, A PLC: We are highly experienced in IRS Offshore/Voluntary Disclosure. Mr. Golding is one of less than 350 Attorneys (out of 200,000) who are Board Certified Tax Law Specialists (A designation earned by less than 1% of Attorneys Nationwide). Sean holds a Master’s in Tax Law, is licensed in New York & California, and is also an Enrolled Agent (Highest Credential awarded by the IRS). His practice is limited to Offshore Tax Law matters worldwide.
IRS Offshore Voluntary Disclosure Lawyers: Even though OVDP has ended, the IRS has updated the Offshore Voluntary Disclosure Procedures. if you are willful, you still have options. Our Tax Lawyers represent clients worldwide in all aspects of IRS Offshore Voluntary Disclosure Practice. The program allows you to disclose domestic & foreign income. We diligently work to protect our clients, and develop cost-effective tax & penalty reduction strategies.
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 eliminating IRS Foreign Money penalties for FBAR & FATCA non-compliance under approved IRS Streamlined Offshore Disclosure guidelines, using Streamlined Domestic or Streamlined Foreign Procedures.
IRS Reasonable Cause Statement: Depending on the facts and circumstances surrounding your nondisclosure, our Tax Lawyers may recommend Reasonable Cause or Delinquency Procedures as an alternative to either IRS Voluntary Disclosure or the Streamlined Program. Reasonable Cause is a fact specific submission, which is based on each applicant's facts & circumstances. Reasonable Cause may eliminate various international, foreign and offshore penalties.
Full-Service Law Firm: Our Offshore Voluntary Disclosure Tax Attorneys represent hundreds of Taxpayers annually in 70-countries. We have developed a unique Tax Law Firm model that is devoted entirely to representing clients with undisclosed money, including tax preparation, legal representation, and audit/examination protection. Our Law Offices are headquartered in a state-of-the-art facility in Irvine, CA (Orange County, California). All work is performed in-house.
Sean holds a Master's in Tax Law from one of the top Tax LL.M. programs in the country at the University of Denver, and has also earned the prestigious Enrolled Agent credential. Mr. Golding is a Board Certified Tax Law Specialist Attorney (A designation earned by Less than 1% of Attorneys nationwide.)
Jenny 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 from USC Gould School of Law (a Top 20 Law School).
IRS Offshore Disclosure Attorney (Scams, Tips & Warnings)
IRS Offshore Voluntary Disclosure International Tax Law Blog
IRS Offshore Disclosure & Voluntary Compliance 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
“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
“During the entire process, we were extremely impressed with their in-depth knowledge of not only OVDP but also with various other IRS Tax Amnesty Programs, as well as with their professionalism and diligence. It is both an honor and a privilege for us to give them our highest possible recommendation.” – OVDP Client
“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
Common International Tax Law Issues in IRS Offshore Voluntary Disclosure
The FBAR is the Report of Foreign Bank and Financial Account form. Taxpayers are required to file an FBAR in each year that their annual aggregate total of foreign financial accounts exceeds $10,000 on any day of the year. There are many misconceptions about what is considered a foreign account, and how the calculation is computed.
FATCA is not the same as FBAR. FATCA is the "Foreign Account Tax Compliance Act." It Is required to be filed each year by any U.S. person that meets the Form 8938 threshold filing requirements for reporting -- and is required to file a tax return in that year. This form is part of your U.S. 1040 tax return, which makes it different from other reporting forms.
A PFIC is a Passive Foreign Investment Company. If you have an interest in a PFIC, the IRS requires that you perform a very complex tax analysis regarding your income and file Form 8621. There are numerous types of investments which qualify as a PFIC, such as holding companies, investment companies, mutual funds, and ETFs.
The IRS requires U.S. owners and investors of certain foreign corporations to submit a Form 5471 to report their ownership in a foreign corporation. This is a difficult form, mainly because it requires a relatively comprehensive breakdown of the corporation's assets, liabilities and equity. There are five (5) different categories of filers who may need to file this form.
The IRS also requires owners and investors of foreign partnerships who qualify as U.S.persons to file an annual form 8865 to report their interest in the foreign partnership. Foreign partnership analyses are extremely complicated and complex. The form has several categories of filers, and each category may have different (and additional) reporting requirements.
The filing requirements for reporting a foreign trust are detailed and comprehensive. The IRS frowns upon foreign trusts, mainly because these trusts are often mis-used to circumvent U.S. tax laws and reporting requirements. The Form 3520-A requires a comprehensive breakdown of the trust's assets, income, assets, and liabilities.
While a foreign person without U.S. status (or situs) is generally not required to file a gift for estate tax return, the U.S. person recipient of a gift, inheritance or trust distribution from a foreign person, business, or trust must file a Form 3520 in any year in which the distribution meets the threshold requirements for reporting. Requirements vary depending on the type of distribution received.
In many countries such as India and Singapore, it is very common to have a foreign life insurance policy. Unlike a U.S. life insurance policy, the U.S. tax and reporting repercussions of having foreign life insurance can be overwhelming. Generally, the policies have to be reported on the FBAR and FATCA, the accrued gains are taxable (subject to PFIC rules), and excise tax is paid on the premiums.
With the IRS winning a subpoena against Coinbase, along with the the U.S. joining in on the International task force J5 (which focuses on preventing offshore "crypto-crime,") the IRS has stepped up the enforcement of federal cryptocurrency compliance. These rules are still being developed, but is always better to play it safe and preemptively file certain reporting forms to ensure fines and penalties can be minimized.
The IRS tax rules involving foreign pensions and retirement is also a complex area of international tax law. Some countries have entered into tax treaties with the U.S., which provide guidance on the Pension taxation rules (UK), some countries have entered into treaties, but important issues are silent (Australian Superannuation) -- and some countries are not so lucky (Singapore CPF).
Understanding how to properly read and interpret international tax treaties is a complex undertaking. Even the most proven and experienced tax attorneys take years to fully embrace the real-world aspects of international tax laws, and how various different tax laws are applied using comity -- along with other legal tenets to different countries with disparate tax systems. We are well-versed on Bilateral Income Tax Treaties.
IRS Offshore Disclosure is a specialized and complicated area of tax law. It requires a thorough understanding and background in tax preparation, tax laws, litigation & trial work. It is important to properly vet out your attorney to ensure they have all the requirements, experience, and certifications necessary to effectively represent you. Watch out for less experienced counsel using false advertising & marketing ploys to bait you in.
Sean holds a Master's in Tax Law from one of the top Tax LL.M. programs in the country at the University of Denver, and has also earned the prestigious Enrolled Agent credential. Mr. Golding is also a Board Certified Tax Law Specialist Attorney (A designation earned by Less than 1% of Attorneys nationwide.)
Latest posts by International Tax Lawyers - Golding & Golding, A PLC (see all)
- Courts Reject Kovel – No Attorney-Client Privilege for the Accountant - April 14, 2019
- Numbered Accounts Offshore – FBAR & FATCA Civil & Criminal Penalty - April 12, 2019
- Voluntary Disclosure Lawyer Scam Warning “Flat-Fee without Tax Prep” - April 9, 2019