We Can Help You.
We represent clients nationwide and in over 65 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.
Even though OVDP has ended, you can still submit to the IRS Voluntary/Offshore Disclosure Program (even if you were willful and/or knew you had a reporting requirement)
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 offshore disclosure to include a stand-along program 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.
What Type of Attorney Should I Hire?
IRS Voluntary Disclosure is a specialized area of law. An IRS Voluntary Disclosure is a complex undertaking. It requires the coordination of several moving parts, including strategy development, Tax Preparation, Legal Analysis, Negotiation and more.
You should hire a Tax Attorney who has the following credentials:
- ~20 Years of Private Practice experience representing his/her own clients
- Experienced in Criminal and Civil Tax Litigation
- Experienced representing clients in Eggshell and Reverse Eggshell Audits
- Advanced Tax Degree (LL.M.)
- EA (Enrolled Agent) or CPA (Certified Public Accountant)
- Preferably a Board Certified Tax Law Specialist
Sean M. Golding, JD, LL.M., EA (Board Certified Tax Law Specialist)
Our Managing Partner, Sean M. Golding, JD, LLM, EA earned 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, and authorizes him to represent clients nationwide.)
Mr. Golding and his team have successfully handled several hundred IRS Offshore/Voluntary Disclosure Procedure cases. Whether it is a simple or complex case, safely getting clients into compliance is our passion, and we take it very seriously.
He is frequently called upon to lecture and write on issues involving IRS Voluntary Disclosure.
Less than 1% of Tax Attorneys Nationwide are Board Certified Tax Law Specialists
The Board Certified Tax Law Specialist exam is offered in many states, and is widely regarded as one of (if not) the hardest tax exam given in the United States for practicing Attorneys. Certification also requires the completion of significant ethics and experience requirements.
In California alone, out of more than 200,000 practicing attorneys (with thousands of attorneys practicing in some area of tax law), less than 350 attorneys are Board Certified Tax Law Specialists.
Beware of Copycat Law Firms
Unlike other attorneys who call themselves specialists or experts in Voluntary Disclosure but are not “Board Certified,” handle 5-10 different areas of tax law, purchase multiple keyword specific domain names, and even practice outside of tax, we are absolutely dedicated to Offshore Voluntary Disclosure.
*Click here to learn the benefits of retaining a Board Certified Tax Law Specialist with advanced tax credentials.
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.
We offer consultations in 30-minute, 60-minute, and 90-minute increments.
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.)