Contents1 IRS Voluntary Disclosure Program (2019-2020)2 Updated Voluntary Disclosure Practice3 Why Should I Make a Voluntary Disclosure?4 How to Make an IRS Voluntary disclosure5 Golding & Golding: About Our International Tax Law Firm IRS Voluntary Disclosure Program (2019-2020) IRS Voluntary Disclosure Program: The IRS Voluntary […]
  Contents1 Voluntary Disclosure Tax Amnesty2 What are the Different Types of Amnesty Programs3 Domestic Voluntary Disclosure Tax Amnesty4 Offshore Voluntary Disclosure Tax Amnesty5 Golding & Golding: About our International Tax Law Firm Voluntary Disclosure Tax Amnesty Voluntary Disclosure Tax Amnesty: There are several Voluntary Disclosure […]
  Contents1 India Offshore Compliance & the IRS2 10  Indian Investments Subject to U.S. Tax & Reporting3 10 Tax Tips (and Misconceptions) to be aware of:4 What if You Have Unreported Income or Assets?5 Golding & Golding: About our International Tax Law Firm India Offshore Compliance […]
??   Contents1 FBAR Penalties2 What is an FBAR?3 How does the IRS Penalize You?4 Civil Penalty Violations (31 U.S.C. § 5321 et seq.)5 Criminal Penalty Violations (31 C.F.R. §103.59)6 Avoiding, Reducing or Eliminating the FBAR Penalty7 Golding & Golding: About Our International Tax Law Firm FBAR […]
U.S. Tax Journey: The international tax lawyers at Golding & Golding have worked with thousands of clients on matters involving offshore tax and reporting compliance. While every situation is unique, and each person has their own story – oftentimes the catalyst that brings an individual foreigner into […]
Tax Court Offshore Penalty Negotiation Trials & IRS Settlement: The number of Offshore Penalty tax court cases for non-filing or non-compliance with IRS International Information Return Reporting is on the rise. Tax Court can get become infinitely more complicated when the matter involves international penalties than it […]
?   Contents1 CP15 Notice2 Out of Compliance BEFORE a Penalty was Issued?3 Golding & Golding: About our International Tax Law Firm CP15 Notice CP15 Notice:  The CP15 Notice is an IRS Penalty Charge that requires a timely response. In a very common scenario, a U.S. […]
  Contents1 Form 8938 2 Specified Foreign Financial Asset Definition3 Form 8938 Threshold and Who Has to File4 Deadline for 8938 Filing5 IRS Penalties for Late Filing Form 89386 Reasonable Cause Exception to Late Form 89387 Golding & Golding: About Our International Tax Law Firm Form 8938  […]
FATCA Reporting: FATCA Reporting is a key enforcement priority, and offshore penalties for not disclosing foreign financial assets is on the rise. In 2020, the IRS will continue aggressive enforcement of FATCA reporting. FATCA (Foreign Account Tax Compliance Act) for U.S. taxpayers commenced in 2011, on the […]
New Court Case for IRS Willful FBAR Penalties (2020 Update): A recent New Court Case for IRS Willful FBAR Penalties  was filed in U.S. v. Fairbank. When it comes to the U.S Government and enforcement of willful FBAR penalties in District Court, the government seems to operate […]
Court Sustains Civil FBAR Willful Penalties in Ott: In U.S. vs. Ott, the Court Sustains Civil FBAR Willful Penalties issued by the IRS. There was no dispute that Defendant failed to file the FBAR. The key question was whether the Taxpayer was willful vs. non-willful. This […]
Increased IRS Audit Risk for High-Income Tax Returns: In 2020, the IRS increases visits to high-income taxpayers who haven’t filed tax returns. In addition to aggressive enforcement of foreign accounts compliance and unreported foreign income enforcement, the IRS has a new (familiar) target – high-income tax […]
U.S. Government Seeks Prison for FATCA Investment Fraud: The U.S. Government Seeks Prison for FATCA Investment Fraud (aka Offshore Tax Evasion and Money Laundering) in a landmark FATCA criminal case.  As we have reiterated for many years on our website, the U.S. Government takes an aggressive […]
Rev. Proc. 2020-17: IRC 6048 Exemptions & 3520 Penalty Relief: The Rev. Proc 2020-17  is an IRS Revenue Procedure that provides Relief for certain Reporting of Foreign Trusts and Foreign Trust Penalties.  The new revenue procedure was released in March. Rev. Proc 2020-17 limits the amount […]
  Quiet Disclosure vs Streamlined: The comparison of Quiet Disclosure vs Streamlined is comparing an approved IRS method for offshore compliance (Streamlined) as opposed to an illegal disclosure (quiet disclosure). In recent years, the Internal Revenue Service has sought to aggressively enforce foreign accounts compliance and […]
Are you being Misled About Streamlined Filing Procedures? At Golding & Golding, we are one of the only IRS tax and law firms worldwide that specializes exclusively in offshore voluntary disclosure.  Ever since the introduction of the “stand alone” streamlined procedures back in 2014, many clients […]
Responding to an IRS Notice for foreign Account, Asset & Trust Penalties: Unfortunately, responding to an IRS notice for foreign account, asset & trust penalties is time-sensitive. That is because generally the U.S. taxpayer only has a limited amount of time to respond to the Internal […]
  Contents1 Offshore Accounts & the IRS 2 Definitions3 What if I Never Reported to the IRS 4 Be Proactive, Get Into Compliance with Offshore Disclosure5 Golding & Golding: About Our International Tax Law Firm Offshore Accounts & the IRS  Offshore Accounts: IRS Reporting Rules & Requirements: The […]
  Contents1 Gift From Foreign Person2 Is it Taxable?3 When is the Gift Reported to the IRS?4 Golding & Golding: About Our International Tax Law Firm Gift From Foreign Person Gift From Foreign Person: The gift from foreign person rules are complex. A gift from a […]
FBAR Retirement: Reporting Plan Accounts & Assets:The FBAR Retirement Reporting of Foreign Accounts within pension plans can be complicated. Generally, the IRS does not require taxpayers to include the foreign accounts within a U.S. pension or retirement account to report foreign accounts. Despite the recent aggressive […]
  Contents1 Quiet Disclosure & the IRS2 Common Example of a Quiet Disclosure3 10 Reasons to Avoid Illegally Disclosing Offshore Assets and Income4 IRS Enforcement of Offshore Penalties5 Statute of Limitations6 Golding & Golding: About Our International Tax Law Firm Quiet Disclosure & the IRS Quiet […]
  Contents1 OVDP vs Streamlined2 What are the Current Offshore Disclosure Options?3 Golding & Golding: About Our International Tax Law Firm OVDP vs Streamlined OVDP vs Streamlined: The  OVDP vs Streamlined comparison is complex. While the IRS continues to aggressively enforce foreign accounts compliance, they closed […]
J-5 and the Joint Chiefs of Global Tax Enforcement: The J-5 and the Joint Chiefs of Global Tax Enforcement protocol is in full-effect, and continues to gain steam. In order further enforce foreign accounts compliance, and reduce offshore tax evasion, the J5 movement continues to gain […]
Attorneys Using Outside CPAs Put Streamlined Filings at Risk: Did your Attorney refer you to an outside CPA? Is your submission now delayed, and your streamlined or VDP (Voluntary Disclosure) sitting in limbo? With rumblings of the IRS ending the streamlined program, and foreign accounts compliance […]
Smurfing Financial Deposits: The smurfing financial deposits crime is complicated. If you were like me, and your childhood included running downstairs on Saturday mornings to catch new episodes of the Smurfs — smurfing is different. The Smurfs were fun (and blue).  Smurfing bank account deposits is criminal…and […]
U.S. Citizen Abroad and Never Filed a Tax Return: Are you a U.S. Citizen Abroad and Never Filed a Tax Return? If you are a U.S Citizen (or former citizen or permanent resident who did not properly expatriate), the IRS has developed several safe and effective […]
  Contents1 FBAR Violations2 Willful vs. Non-Willful3 Can the Taxpayer Show Reasonable Cause?4 FBAR Violation Penalties5 Golding & Golding: About Our International Tax Law Firm6 Less than 1% of Tax Attorneys Nationwide Are Certified Specialists FBAR Violations FBAR Violations: Enforcement of FBAR Violations are on the […]
RRSP FBAR Reporting, FATCA Form 8938 & U.S. Tax (2020): The RRSP Reporting rules on FBAR and Form 8938 are relatively straightforward, as are the income tax rules. To further simply the reporting rules, 2020, the IRS introduced a new revenue procedure 2020-17 which further simplifies […]
FBAR Penalty Cases & Recent Court Rulings: Several FBAR Penalty Cases were decided in 2019. In 2020, there are bound to be several more FBAR cases, case rulings & penalty decisions nationwide. The IRS has taken an aggressive stance against U.S. persons who are not in […]
FBAR Reporting: The FBAR Reporting requirements are more complex than ever. The IRS requires U.S. persons with foreign accounts (who meet the threshold) to file an annual FBAR. The Internal Revenue Service has taken an aggressive position with enforcing foreign accounts compliance. FBAR reporting includes more […]
Form 8621 Instructions: The Form 8621 & even the Instructions are complex. The IRS requires U.S. owners of a PFIC (Passive Foreign Investment Companies) have to report ownership on Form 8621. Common examples include foreign mutual funds and holding companies. In recent years, the IRS has […]
?   Contents1 Form 146532 How to Draft the Personal Certification Statement3 A few Tips for Drafting the 14653 Certification 4 Signing Under Penalty of Perjury5 Golding & Golding: About Our International Tax Law Firm Form 14653 Form 14653: The Form 14653 is a key IRS form […]
Form 3520-A: The Form 3520-A is used to report foreign trusts. Specifically, the IRS Form is referred to as Annual Information Return of Foreign Trust With a U.S. Owner (Under section 6048(b)). Contents1 Form 3520-A2 IRC 60483 What is Foreign Trust Reporting?4 How do I Report […]
FATCA Lawyers: Our FATCA Lawyers represent clients across the globe. In recent years, the IRS has increased enforcement of FATCA and Foreign Accounts Compliance. FATCA is the Foreign Account Tax Compliance Act. For U.S. tax filers, it generally includes filing an annual Form 8938. The rule […]
?   Contents1 FBAR Willful Penalty & the IRS2 How does the IRS Define Willfulness?3 What is Reckless Disregard?4 What is Willful Blindness?5 Recent FBAR Court Cases (5 Important Case Holdings)6 FBAR Penalties can be Mitigated7 Golding & Golding (Board-Certified Tax Law Specialist) FBAR Willful Penalty […]
?   Contents1 Domestic Tax Amnesty & the IRS2 Common Terms & Definitions3 How to Submit4 Four (4) Examples Domestic Voluntary Disclosure 5 Golding & Golding: About Our International Tax Law Firm Domestic Tax Amnesty & the IRS Domestic Tax Amnesty IRS Voluntary Disclosure: The Domestic […]
Form 5471 Penalties: The Form 5471 Penalties can be tough. In recent years, the IRS has increased enforcement of foreign accounts compliance, including reporting foreign corporations. Unlike other international reporting forms such as the FBAR and 8938 — which are primarily used to report value — […]
Contents1 Subpart F Income2 What is a CFC (Controlled Foreign Corporation?3 What is Subpart F?4 Categories of Subpart F Income5 Common Subpart F Questions and Answers 6 Tax Reform7 Exceptions, Exclusions, and Limitations8 Golding & Golding: About Our International Tax Law Firm Subpart F Income Subpart F […]
  Contents1 International Tax Attorney Miami2 Golding & Golding: About Our International Tax Law Firm International Tax Attorney Miami Miami International Tax Attorney Miami: Our Florida IRS Offshore Compliance Lawyers represent clients statewide, including Miami.  Offshore Voluntary Disclosure is a highly niched area of law that combines Legal […]
FBAR Late Filing Penalty: An FBAR Late Filing penalty can be substantial.The IRS requires an FBAR to be filed timely in accordance with offshore account, asset & investment reporting requirements. If the FBAR is filed late, untimely, or incomplete, the Internal Revenue Service may issues fines […]
Houston International Tax Fraud Scheme Prosecuted: In a recent criminal tax case, a Houston Tax Preparer may be facing time behind bars. The U.S. Government criminally prosecuted (and won) a case against a Tax preparer in Houston who was perpetrating an international tax fraud. What makes […]
?   IRS OVDP (2019) – Summarizing Offshore Voluntary Disclosure – Golding & Golding Contents1 OVDP (Offshore Voluntary Disclosure Program)2 OVDP Has Been Revised for 2019-20203 Preclearance Letter4 Processing the Offshore Disclosure5 Time Period of Disclosure6 Civil Resolution Framework7 Penalties on Taxes Due8 Penalties on FBAR9 […]
Form 8843 & Instructions 2020: The Form 8843 instructions can be complex. The IRS allows some foreigners who meet the substantial presence test (SPT) to claim an exemption to U.S. tax on worldwide income. The form is different than form 8840, which is used to show a […]
  Contents1 Delinquent FBAR Submission Procedures2 How Many Years Back Can You File?3 What are the Penalties for Delinquent FBAR Filing?4 Golding & Golding: About our International Tax Law Firm Delinquent FBAR Submission Procedures Delinquent FBAR Submission Procedures: The IRS Delinquent FBAR Submission Procedures are a […]
Foreign Asset Reporting: The U.S. government strictly enforces foreign asset reporting to the IRS. The IRS requires U.S. owners of foreign assets to report offshore accounts, assets, investments, and income to the U.S. government each year on various different forms. Over the past few years, the […]
    Contents1 Streamlined Domestic Offshore Procedures2 Purpose of the IRS Streamlined Program3 Eligibility Criteria for U.S. Residents 4 Treatment & Scope of IRS Streamlined Procedures5 IRS Form 14654 Non-Willful Certification 6 First Try Streamlined, then go OVDP?7 Golding & Golding: About our International Tax Law Firm8 Interested […]
Accidental Americans FATCA (How to Avoid Taxes & Penalties): The Accidental Americans FATCA, FBAR and U.S. Tax and IRS reporting analysis is complex. As the name connotes, an Accidental American is a U.S person who did know they were a U.S. person until they were adults. […]
  Contents1 OVDP Lawyers & IRS Offshore Disclosure2 How to Interview IRS Offshore Counsel3 Golding & Golding: About Our International Tax Law Firm OVDP Lawyers & IRS Offshore Disclosure OVDP Lawyers: Our OVDP lawyers specialize exclusively in Offshore Disclosure. The IRS international tax lawyers at Golding […]
? Contents1 Covered Expatriate2 Expatriation Tax 3 What are the Three (3) Tests?4 Golding & Golding: About Our International Tax Law Firm Covered Expatriate Covered Expatriate 2019 IRS Tax Rules Giving Up U.S. Status: When a person is a covered expatriate, it complicates expatriation. The IRS rules […]