IRS Disclosure Tax Law Services – Golding & Golding (Tax Law Specialist)
Golding and Golding are a highly experienced IRS Disclosure Lawyers. We represent clients worldwide with simple-to-complex IRS Disclosure tax matters.
We serve as advisors to several high-profile Clients and other Professionals in over 65 countries; IRS Offshore/Voluntary Disclosure is our passion.
We limit our practice exclusively to IRS Disclosure of unreported accounts, assets, investments and income.
IRS Disclosure is a Specialty
Most experienced IRS Voluntary/Offshore Disclosure Lawyers will have:
- Around 20 years experience representing their own clients as Lawyers
- Completed a Master’s Degree in Tax (LL.M.)
- Achieved either the Enrolled Agent Credential (EA) or are a licensed CPA
- Preferably a Board Certified Tax Law Specialist (Less than 1% Nationwide)
Traditional IRS (IRM) Voluntary Disclosure Program
Whether you are a U.S. Resident or business with unreported Domestic Income, or a Foreign Person with unreported U.S. Business Income, Assets or Earnings, it is important to remain in tax compliance. The traditional Voluntary Disclosure Program is used in lieu of OVDP or the Streamlined Programs.
OVDP is an acronym for Offshore Voluntary Disclosure Program. It is the traditional Internal Revenue Service program designed to bring individuals, estates, and businesses into Offshore and Foreign Compliance.
*As of 9/28 OVDP has been discontinued, although OVDP Opt-Out is still available.
If you have unreported Foreign Accounts, Income, Investments or Assets and want to get into IRS compliance, the Streamlined Domestic Offshore Procedures (SDOP) may be a good option for you. We have successfully handled hundreds of Streamlined Domestic Offshore Procedure cases. (5% Penalty Option)
If you reside overseas and have unreported Foreign Accounts, Income, Investments or Assets and want to get into IRS compliance, the Streamlined Foreign Offshore Procedures (SFOP) may be a good option for you. We have successfully handled hundreds of Streamlined Foreign Offshore Procedure cases as well. (Penalty Waiver)
Reasonable Cause Statement
For some taxpayers who were non-willful in failing to comply with IRS and DOJ rules for Reporting Foreign Accounts, Foreign Income, Foreign Assets, and Foreign Property, submitting a Reasonable Cause Statement in lieu of submitting to the Streamlined Offshore Disclosure Programs may be a viable option. (Penalty Waiver, Some Risk)
When a person makes a “Quiet Disclosure” they are making the fateful decision to forego the IRS Offshore Voluntary Disclosure programs, and instead make an illegal submission by knowingly amending prior year tax returns, FBAR, FATCA Reporting, etc. without going through the proper channels. (Fixing Quiet Disclosures)
For some clients, they missed their chance to voluntarily disclose to the IRS — but still want to get into IRS offshore compliance. This is not necessarily because they want to, but because they have to. Typically, this occurs when a person has already been issued IRS Offshore/Foreign Penalties, is under a Special Agent investigation for tax fraud and/or evasion, is subject to a high-stakes audit or examination (eggshell or reverse-eggshell), in the middle of a divorce with hidden offshore assets, or is otherwise forced out into the open.
With so many inexperienced Attorneys misrepresenting their background and experience in matters involving Streamlined Disclosure, Reasonable Cause, and Voluntary/Offshore disclosure, we have been inundated with inquiries about helping fixing these disclosures. Whether it was an Attorney who took you Streamlined or Reasonable Cause when you were willful, scared you into OVDP or IRM Disclosure when it was not an appropriate submission (or any number of other Attorney Malpractice scenarios) we can help.