Former IRS Personnel & Streamlined Offshore Procedure: Fact vs. Fiction

Former IRS Personnel & Streamlined Offshore Procedure: Fact vs. Fiction

Recently, we were contacted by a client who was seeking assistance in a Streamlined Offshore Procedures matter. When we spoke with her, it sounded like she received some bad streamlined advice by inexperienced counsel. The other Attorney represented that while the attorney would not handle the tax returns in-house, the lawyer would send the client to a CPA, using a Kovel letterThe attorney misrepresented how the attorney-client privilege works with tax return preparation, and failed to represent Kovel provides no protection for tax preparation documents — and can be rejected.

Former IRS Personnel “Marketing”

When a tax attorney prefaces that they “used to work at the IRS,” or are “former IRS personnel” you get the impression they worked for the IRS in whichever field they are currently practicing, and gained, “significant attorney experience” in that particular area of tax law, right?

They want you to conjure up images of themselves sitting around the table with other experienced offshore disclosure attorneys, brainstorming complex offshore disclosure matter ideas.

When a private practice tax attorney used to work at the IRS, and practices in the same department they did while at the IRS, it can only benefit the client. Such as a private practice Trial Lawyer who used to work as Trial Counsel for the IRS.

Likewise, the IRS has nearly 100,000 employees and just being one of them does not benefit your Streamlined Offshore case, at all.

Here are some examples of entry level positions at the IRS to help you in your research:

Former IRS Personnel & Working at the IRS

IRS Examiner


This position reviews tax returns for accuracy and completeness, reviews and codes tax returns for computer processing, resolves errors and corresponds with taxpayers to obtain any missing information”

Revenue Agent


In the IRS’ Small Business and Self-Employed (SB/SE) division, you’ll conduct examinations of individuals and small businesses to determine federal tax liability.

IRS Tax Law Specialist


As a Specialist, you’ll leverage the latest in mini and micro computers, telecommunications and data management systems. You’ll be a proactive decision-maker working with customers, businesses and the legal and financial communities.


Be Diligent when Hiring Streamlined Counsel

It is important that you feel comfortable, safe and protected with your Streamlined Offshore counsel. Be sure to ask the attorney the hard and important questions. 

  • How many Streamlined cases have they handled?
  • Is Streamlined & Voluntary Disclosure the only areas of tax law they handle?
  • If they refer the case out to a CPA or EA, do they accompany you, and is it included in the flat-fee?
  • If they worked for the IRS, what was their role at the IRS?
  • Are they dually-licensed as an EA/Attorney or CPA/Attorney?
  • Do they have a Master’s in Tax Law?
  • Are they Board-Certified?

Golding & Golding: Board-Certified Tax Attorney Specialist

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 70-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.

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+.
How to Hire Experienced Streamlined Counsel?

How to Hire Experienced Streamlined Counsel

Hiring Experienced Streamlined Offshore Counsel

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

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

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.