Expatriation & IRS Enforcement of Exit Tax- New Practice Area Campaign (Board Certified Tax Specialist)

Expatriation & IRS Enforcement of Exit Tax – New Practice Area Campaign (Board Certified Tax Specialist)

Expatriation & IRS Enforcement of Exit Tax – New Practice Area Campaign

Each year, Golding & Golding represents several clients in complex IRS matters involving in a hybrid offshore disclosure and expatriation submission.

Typically, when a client approaches us, they are unable to confirm on form 8854 that they have five (5) years of U.S. tax compliance.

Therefore, we work with our clients to develop a multitiered strategy to get clients into offshore compliance, and out of the United States tax system.

Expatriation Practice – IRS Practice Area Campaign

The rules for expatriation changed significantly Post-2008.  

As a result, the IRS believes that there are many taxpayers who may have improperly expatriated, not computed and or accurately paid the exit tax, and/or attempted to employ some less than kosher planning techniques — using various trusts — in an attempt to avoid expatriation tax.

Therefore, the IRS launched an expatriation practice campaign.

As provided by the IRS:

Practice Area: Withholding & International Individual Compliance


Lead Executive: John Cardone, director of Withholding & International Individual Compliance


U.S. citizens and long-term residents (lawful permanent residents in eight out of the last 15 taxable years) who expatriated on or after June 17, 2008, may not have met their filing requirements or tax obligations. The Internal Revenue Service will address noncompliance through a variety of treatment streams, including outreach, soft letters, and examination


Out of Tax Compliance, and Seeking Expatriation?

If you are out of U.S. tax compliance and considering expatriation, it is important to understand what the exit tax is, and who it applies to. 

Just giving up your green card is not sufficient when you are a long term resident. 

That said, there are various exceptions and exclusions which you may consider.


Getting Into IRS Offshore Compliance

It is human nature to want to avoid making a proactive submission to a government agency such as the IRS before the IRS ever discovers the non-compliance. But, typically that is best path forward.

Golding & Golding, Board Certified in Tax Law

We have successfully represented clients in more than 1,000 streamlined and voluntary disclosure submissions nationwide and in over 70-different countries.

Golding & Golding is the “go-to” firm for other Attorneys, CPAs, Enrolled Agents, Accountants, and Financial Professionals across the globe.

Golding and Golding, Board-Certified Tax Law Specialist

Golding and Golding, Board-Certified Tax Law Specialist

Golding & Golding: Our international tax lawyers practice exclusively in the area of IRS Offshore & Voluntary Disclosure. We represent clients in 70+ different countries. Managing Partner Sean M. Golding is a Board-Certified Tax Law Specialist Attorney (a designation earned by < 1% of attorneys nationwide.). He leads a full-service offshore disclosure & tax law firm. Sean and his team have represented thousands of clients nationwide & worldwide in all aspects of IRS offshore & voluntary disclosure and compliance during his 20-year career as an Attorney.

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. He has also earned the prestigious IRS Enrolled Agent credential. Mr. Golding's articles have been referenced in such publications as the Washington Post, Forbes, Nolo, and various Law Journals nationwide.
Golding and Golding, Board-Certified Tax Law Specialist