FBAR Lawyer Houston: The IRS has increased enforcement of FBAR Reporting of offshore accounts, assets, and investments. The FBAR is a “federal” filing. It is required by the Internal Revenue Service. When a Foreign Account holder is out of compliance for reporting accounts, they may become subject to FBAR fines and penalties. At Golding & Golding, we specialize exclusively in FBAR Amnesty, Streamlined Filing Compliance, and Voluntary Disclosure. We represent many clients throughout Houston, Sugar Land, and the neighboring Houston communities. Each case is led by a Board-Certified Tax Law Specialist.
FBAR Lawyer Houston (Golding & Golding)
Golding & Golding is based out of Irvine, California. We specialize exclusively in international tax, and specifically IRS offshore disclosure.
We have successfully represented clients in more than 1,000 streamlined and voluntary offshore disclosure submissions nationwide and in over 75-different countries. We have represented thousands of individuals and businesses with international tax problems.
We are the “go-to” firm for other Attorneys, CPAs, Enrolled Agents, Accountants, and Financial Professionals across the globe.
- Learn more about the Board-Certified Tax Lawyer Specialist credential
- Learn more about the Enrolled Agent credential
- Learn more about Golding & Golding’s Case Accomplishments
- Learn more about Golding & Golding Testimonials from prior clients
We are the “go-to” firm for other Attorneys, CPAs, Enrolled Agents, Accountants and Financial Professionals worldwide.
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+.
Who Needs an FBAR Attorney?
The following summary details when and why you need an FBAR Attorney.
A. You Filed the FBAR Timely, But…
But, maybe you forgot a few accounts or assets and are not sure, or did not also include them on the FATCA Form 8938, 3520, 8621, etc. — you may want to speak with an FBAR Attorney to discuss willful vs. non-willful, etc. but if there is no unreported income, you should be fine.
B. You Missed the FBAR Filing Deadline
The deadline for filing the FBAR is the date your taxes are due (usually April 15th), but is currently on automatic extension to October.
If you missed the FBAR Deadline, you may be subject to fines and penalties and will want to speak with an experienced FBAR Attorney.
C. You are Worried about FBAR Penalties
FBAR Penalties can be Civil or Criminal.
They can then be broken down even further, but the threshold question, is whether the IRS will get you for Civil (money) or Criminal (money, and worse).
i. Civil FBAR Penalties
Civil FBAR Penalties are limited to monetary penalties. A civil FBAR Penalty is a penalty that is focused on monetary fines or warning letters (waivers) — without any risk of criminal investigation or prosecution.
A few important considerations:
– Most courts have held that the maximum annual FBAR willful penalty is not limited to $100,000.
– If the court believes you acted with Reckless Disregard, they can still penalize you full Willful FBAR Penalties.
– If the court believes you acted with Willful Blindness, they can still penalize you full Willful FBAR Penalties.
– Even in a non-willful setting, the court can issue $10,000 per account, per year penalty
ii. Criminal FBAR Penalties
Criminal FBAR Penalties may include monetary penalties and incarceration.
This is when the IRS refers the matter to the Department of Justice (DOJ) or other 3 letter government faction for criminal investigation and possible prosecution. These are not very common, but unfortunately they are on the rise.
Interested in a Houston FBAR Lawyer?
No matter where in the world you reside, our international tax team can get you IRS offshore compliant with all FBAR, FATCA and other foreign reporting and disclosure requirements.
Golding & Golding specializes in IRS offshore voluntary and streamlined disclosure procedures. Contact our firm today for assistance with getting compliant.
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.