What is a Dually-Licensed Tax Attorney for IRS Offshore Disclosure
IRS Offshore Disclosure is a very difficult area of law. It requires advanced tax knowledge, such as an LL.M. (Master’s in Tax Law), in addition to several years of:
- Tax preparation and analysis
- Litigation experience
- Trial experience
- Eggshell and Reverse-Eggshell Audit experience
Dually-Licensed Tax Attorney for IRS Offshore Disclosure
The best representation a client can have in IRS Offshore & Voluntary Disclosure is with a dually-licensed Attorney, and the attorney’s support team.
A dually-licensed tax attorney is an attorney licensed as both an Attorney, and as either an Enrolled Agent (EA) or Certified Public Accountant (CPA).
In offshore disclosure, a dually-licensed tax attorney and his or her team handle these matters, in-house on a flat-fee, full-service basis.
The in-house team represents the client in all aspects of the offshore voluntary/streamlined disclosure, including:
- Tax analysis and preparation
- Attorney representation
- IRS follow-up
- Post-submission audit, examination, and investigation
Why is it Important to be Dually-Licensed?
Even simple tax situations are usually much more complicated than they first appear. It takes an attorney dually licensed as an Enrolled Agent or CPA with an extensive legal and tax background to effectively evaluate and asses all the tax and legal issues involving offshore disclosure, in order to piece them together properly to present your disclosure in the best light.
Issuing a Kovel Letter
Issuing a Kovel letter in IRS offshore disclosure is rare, since both the tax and legal matters are handled exclusively in-house.
Experienced tax lawyers do not just issue Kovel Letters on every case they work on, since general tax preparation is excluded from Kovel protection — and it puts the clients confidentiality at risk.
Thus, absent any extremely complicated, multi-faceted business accounting, BEPS, and/or related foreign business tax issues, a Kovel Letter is not appropriate.
And, even when a law firm issues a Kovel Letter, the issuing attorney(s) should be dually-licensed in order to best protect the attorney-client privilege, and client confidentiality.
Golding & Golding, A PLC
We have successfully represented clients in more than 1,000 streamlined and voluntary 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.
- 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
Interested in Filing under IRS Tax & Amnesty Procedures?
No matter where in the world you reside, our international tax team can get you IRS offshore compliant.
Golding & Golding specializes in offshore tax and reporting amnesty. 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.