Offshore Tax Attorney (International Tax Compliance Specialist): An Offshore Tax Attorney is an attorney licensed by at least one State Bar, and focuses exclusively in offshore tax matters. The IRS has increased enforcement of foreign compliance international reporting related matters. Some common offshore tax matters involve the disclosure of foreign assets, accounts, investments and income to the United States. The failure to report or disclose these assets to the Internal Revenue Service may result in significant fines and penalties.
Offshore Tax Attorney
Even within the realm of Offshore Tax, there are “sub-specialties.” For example, some offshore tax lawyers may focus on tax litigation, while other focus on treaty law. At Golding & Golding, we focus exclusively in IRS Offshore & Voluntary Disclosure.
Examples of Matters an Offshore Tax Attorney Handles:
(IRM) Offshore Voluntary Disclosure
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.
Offshore Voluntary Disclosure Program (OVDP)
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.
Streamlined Domestic Offshore Procedures (SDOP)
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)
Streamlined Foreign Offshore Procedures (SFOP)
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)
Expatriation with Offshore Disclosure
If you are ready to relinquish your Green Card or renounce your U.S. Citizenship, we can help. Oftentimes, we represent clients who are seeking to both get into IRS Offshore/Foreign Compliance and Expatriate and mitigate GILTI related issues.
Fixing Quiet Disclosures
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)
Offshore Penalty Reduction
Sometimes, the IRS penalizes Taxpayers and Account Holders before the person has an opportunity to submit to Offshore Tax Amnesty. Other times, less experienced attorneys submit clients incorrectly to an amnesty/voluntary disclosure program — and the IRS issues penalties. Common penalties include FBAR, Form 3520, Form 8938 and Form 5471.
IRS Offshore Disclosure Investigations & Examinations
You may have an IRS Offshore Disclosure issue that does not fit neatly into one specific “offshore disclosure” box. The IRS has made offshore enforcement a key priority — international tax audits, examinations, and automatic penalties are on the rise. If you are under audit or investigation for offshore related income, accounts, assets, or investments, and/or received an IRS notice regarding Offshore Tax matters, there are still options available to reduce, minimize and avoid IRS penalties.
Fixing Other Attorney or Accountant Disclosure Mistakes
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.
Hiring an Offshore Tax Attorney
Due to all the false and misleading advertising, it is important to understand how to hire an offshore tax attorney.
How to Hire Experienced 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
Golding & Golding (Board-Certified Tax Law 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.
- 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
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+.
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.