We Can Help You.
We represent clients nationwide and in over 60 countries from our state-of-the-art offices in Irvine, California. We have successfully represented hundreds of clients annually, from smaller cases, all the way up to nearly $40,000,000 in a single disclosure.
Sean M. Golding, JD, LL.M., EA – Certified Tax Law Specialist
Our Managing Partner, Sean M. Golding, JD, LLM, EA is the only Attorney nationwide who has earned the Certified Tax Law Specialist credential and specializes in IRS Offshore Voluntary Disclosure Matters.
In addition to earning the Certified Tax Law Certification, Sean also holds an LL.M. (Master’s in Tax Law) from the University of Denver and is also an Enrolled Agent (the highest credential awarded by the IRS.)
He is frequently called upon to lecture and write on issues involving IRS Offshore Voluntary Disclosure.
Less than 1% of Tax Attorneys Nationwide
Out of more than 200,000 practicing attorneys in California, less than 400 attorneys have achieved this Certified Tax Law Specialist designation.
The exam is widely regarded as one of (if not) the hardest tax exam given in the United States for practicing Attorneys. It is a designation earned by less than 1% of attorneys.
We Are Highly Experienced in OVDP
IRS Offshore Voluntary Disclosure is ALL we do. While our lead partner, Mr. Golding has been practicing law for nearly 20 years as an attorney, and has extensive experience in complex, high-stakes Eggshell Audits, Reverse Eggshell Audits, Criminal and Civil Litigation, we limit our practice exclusively to IRS Offshore Voluntary Disclosure.
We have successfully handled several hundred OVDP and Streamlined Disclosure cases.
We are the OVDP Attorneys that other CPAs, Attorneys (and even current and former IRS personnel) contact when they need help.
What is OVDP?
OVDP is the Offshore Voluntary Disclosure Program. It is a program designed by the U.S. Government to assist individuals and businesses that have not met their foreign account and offshore income reporting requirements to get into compliance.
If you are considering OVDP, there are a few facts you should know.
OVDP is an IRS Program
OVDP is a program that was designed and authorized by the U.S. government. As such, by entering into OVDP, you will be getting into compliance with U.S. tax law.
OVDP is Usually for People who are Willful
OVDP is a program that was designed for individuals who were willful. Even though the IRS does not provide a concrete definition of the term willful, it generally means individuals and/or businesses that knew they had a reporting requirement but did not report their foreign accounts or offshore/foreign income to the United States. (There are a few instances where a non-willful person may still want to file OVDP instead of the Streamlined Program.)
You May Not Owe Any Taxes
Depending on which country you reside in and whether or not you pay foreign taxes, you may not have any tax liability under the program. That is because you are generally entitled to a foreign tax credit – a credit for taxes you paid in a foreign country. This credit is then applied to any U.S. tax liability you may have.
Here’s a very basic example: Stephen earns $100,000 in investment income from Japan. The Japan Financial Institution already withheld 20.3% in taxes before distributing the interest income. Even though Stephen will have to report the income on his US tax return, he will get a credit for the $20,300 already paid in Japan.
If You were Non-Willful, You May Go “Streamlined”
In recent years, the United States has expanded a small part of traditional OVDP called Streamlined Filing Compliance Procedures (Streamlined Program). The IRS created this temporary program in order to make it easier for individuals who were not willful to get into compliance.
If you qualify for the Streamlined Program, the penalty has been reduced all the way down to 5%. And, if you reside in a foreign country and meet the foreign resident requirement, your entire penalty may be waived and you may not owe any penalty at all.
Therefore, there is a possibility that not only will you have no tax liability, but you also may have no penalty due to the IRS. Zero taxes and zero penalty – it doesn’t get any better than that.
Reduced Fee Consultation
We do not offer “free” initial telephone consultations, because free initial telephone consultations are nothing more than “Sales Pitches” designed to misinform and scare you into making a brash decision.
When you are ready to discuss the specifics of your case, please email us to schedule a Reduced Fee Telephone Consultation with an experienced IRS Offshore Voluntary Disclosure Lawyer.