We represent clients in the IRS Voluntary Disclosure Program (VDP) for offshore, foreign and domestic assets, accounts investments and income.

Streamlined Domestic Offshore Procedures (SDOP)

The Streamlined Domestic Offshore Procedures (SDOP) is for taxpayers who are non-willful and meet the other requirements. The Offshore Penalties are reduced to 5%.

The Streamlined Foreign Offshore Procedures (SFOP) is for non U.S. Resident taxpayers who are non-willful and meet the foreign resident requirement. The Offshore Penalties are waived.

For some taxpayers who were non-willful, they may submit  a Reasonable Cause or Delinquency Procedure submission in lieu of submitting to the Streamlined Offshore Disclosure Programs.

If you are ready to relinquish your Green Card or renounce your U.S. Citizenship, we can help. We represent clients who are seeking to both get into IRS Offshore Compliance and Expatriate.

A Quiet Disclosure is an illegal submission by knowingly amending prior year tax returns, FBAR, FATCA Reporting, etc. without going through the proper channels. We help you fix this mistake.

Offshore Penalty Reduction 

Sometimes, the IRS penalizes Taxpayers before the person has an opportunity to submit to Offshore Tax Amnesty. Common penalties include FBAR, Forms 3520, 8938, and 5471.

The IRS requires U.S. Persons to Report Gifts from Foreign Individuals and Businesses when they meet the threshold requirements. Failing to report may result in significant penalties.

Foreign Pension and Reporting 

The U.S. Tax and Reporting rules for foreign pensions are complicated and may vary based on treaty and impact of various revenue procedures and IRS rulings.

Tax Treaty and International Tax Investigations

We are often called upon to help clients evaluate tax treaties, asses Form 8833 Tax Treaty positions & determine whether different sources of foreign income are taxable in the U.S.

The IRS requires certain U.S. persons with foreign trusts to report the trust to the IRS. The failure to report the trust oftentimes results in automatic fines and penalties.

Amateur and Inexperienced Offshore Tax Lawyers put clients into bad tax situations. We help get them out of their tax messes with the least amount of collateral damage.

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930 Roosevelt Avenue, Suite 321, Irvine, CA 92620