It is Simply Not Worth the Risk

Even though the notion of voluntarily getting into compliance with the Internal Revenue Service (IRS) through Voluntary Disclosure, the Streamlined Program or Reasonable Cause is scary and overwhelming. By making a Quiet Disclosure, you are breaking the law and that is never the correct option.

IRS Quiet Disclosure Puts Taxpayers at Unnecessary Risk

IRS Quiet Disclosure Puts Taxpayers at Unnecessary Risk

What is a Quiet Disclosure?

A Quiet Disclosure is when you knowingly, intentionally, or recklessly file/amend past tax returns to include unreported foreign income, accounts, assets, or investments.

Typically, when a person files a Quiet Disclosure, they have one or multiple forms that were not properly filed with the IRS, including:

  • FBAR (Fincen 114)
  • FATCA Form 8938
  • Form 5471
  • Form 5472
  • Form 8621
  • Form 8865

Offshore Disclosure Penalties May Be Reduced or Waived

If the reason you did not previously report the information or income to the IRS was because you were unaware of the requirement to do so, there are relatively painless methods you can use to safely get into compliance. They include:

  • Streamlined Domestic Offshore Procedures
  • Streamlined Foreign Offshore Procedures
  • Delinquent Information Return Filing
  • Delinquent FBAR Filing
  • Reasonable Cause

Even if you were willful in years past, if you enter OVDP — you nearly eliminate any chance of IRS audit, or criminal investigation for these international tax related issues. Moreover, you may be able to reduce the penalties by opting out, making a mark-to-market election, or implementing FAQ 55 penalty waivers.

Once You Knowingly Make a Quiet Disclosure…

…You are willful. Even if you were non-willful before, by “quietly” submitting prior year tax returns or FBARs, you are intentionally omitting necessary information to the IRS, which could now turn your previous non-willful noncompliance into a full-blown willfulness/tax fraud situation.

**If you “unintentionally” made a previous Quiet Disclosure, you may still qualify for the Streamlined or Reasonable Cause option.

Can I Just Properly Report Going Forward?

Here is the problem with that strategy: if you knew you were supposed to go back and file previous returns or FBARs and did not do so, and your are audited, you could be considered to have acted with reckless disregard and/or as making an intentional omission – which could lead to willful penalties down the line (and those penalties can be very steep).

Our Process is Simple & Completely Confidential

When you are ready to discuss the specifics of your case, visit our contact us page or directly through email at to schedule a Reduced Fee Telephone Consultation with an experienced IRS Offshore Voluntary Disclosure Lawyer.

We offer consultations in 30-minute, 60-minute, and 90-minute increments.

Golding & Golding: About Our International Tax Law Firm

Golding & Golding specializes exclusively in international tax, and specifically IRS offshore disclosure

We are the “go-to” firm for other Attorneys, CPAs, Enrolled Agents, Accountants, and Financial Professionals across the globe. Our attorneys have worked with thousands of clients on offshore disclosure matters, including FATCA & FBAR.

Each case is led by a Board-Certified Tax Law Specialist with 20 years of experience, and the entire matter (tax and legal) is handled by our team, in-house.

*Please beware of copycat tax and law firms misleading the public about their credentials and experience.

Less than 1% of Tax Attorneys Nationwide Are Certified Specialists

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.

Recent Golding & Golding Case Highlights

  • We represented a client in an 8-figure disclosure that spanned 7 countries.
  • We represented a high-net-worth client to facilitate a complex expatriation with offshore disclosure.
  • We represented an overseas family with bringing multiple businesses & personal investments into U.S. tax and offshore compliance.
  • We took over a case from a small firm that unsuccessfully submitted multiple clients to IRS Offshore Disclosure.
  • We successfully completed several recent disclosures for clients with assets ranging from $50,000 – $7,000,000+.

How to Hire Experienced Offshore Counsel

Generally, experienced attorneys in this field will have all the following credentials/experience:

  • 20-years experience as a practicing attorney
  • Extensive litigation, high-stakes audit and trial experience
  • Board Certified Tax Law Specialist credential
  • Master’s of Tax Law (LL.M.)
  • Dually Licensed as an EA (Enrolled Agent) or CPA

Interested in Learning More about Golding & Golding?

No matter where in the world you reside, our international tax team can get you IRS offshore compliant. 

Golding & Golding specializes in FBAR and FATCA. Contact our firm today for assistance with getting compliant.

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