OVDP Lawyers & IRS Offshore Disclosure
OVDP Lawyers: Our OVDP lawyers specialize exclusively in Offshore Disclosure. The IRS international tax lawyers at Golding & Golding represent clients in all aspects of OVDP. OVDP is the Offshore Voluntary Disclosure Program. The program is designed to bring taxpayers into offshore compliance for foreign accounts, assets, investments and income. The program was closed in 2018, but a newer version of the traditional voluntary disclosure program (VDP) was introduced in 2018-2019 as well.
Golding & Golding: OVDP Lawyer Team
The OVDP Lawyers at Golding & Golding represent clients nationwide and worldwide (in over 75 different countries) in disclosing offshore accounts, assets, investments & Income. With the IRS taking an aggressive position on matters involving foreign accounts compliance and unreported foreign income — compliance is crucial to avoid offshore fines and penalties.
The new updated VDP provides additional guidance on voluntary disclosures that involve offshore money. Our International OVDP Lawyer team specializes in IRS Offshore Voluntary Disclosure for FATCA, FBAR, and PFIC penalty mitigation. Each case is led by a Board-Certified Tax Law Attorney Specialist (less than 1% of attorneys nationwide).
Common offshore assets and accounts our OVDP Lawyers are retained to disclose, include:
- Bank Accounts
- Financial Accounts
- Specified Assets
- Life Insurance
- Mutual Funds
- Holding Companies
Taxpayers (in the U.S. and abroad) who are out of IRS compliance with Foreign and Offshore Account reporting should retain an experienced dual Attorney/Enrolled agent IRS Offshore Disclosure Attorney team to assist them.
Even though OVDP has ended, If you are willful, the Internal Revenue Service has updated post-OVDP procedures, which are detailed in the Internal Revenue Manual.
Types of Offshore Disclosure Matters we Routinely Handle:
- IRM Traditional Voluntary Disclosure
- Streamlined Filing Compliance Procedures
- Streamlined Domestic Offshore Procedures
- Streamlined Foreign Offshore Procedures
- Streamlined Voluntary Disclosure
- Reasonable Cause
- Fixing Quiet Disclosures
- Fixing mistakes made by less experienced Attorneys
How to Interview IRS Offshore Counsel
There are five (5) important questions to ask the OVDP Lawyers you are considering hiring for an offshore voluntary disclosure case
How Many Years of Litigation & Trial Experience do they have?
When it comes to offshore disclosure, one of the key components is developing and executing an offshore submission legal strategy. OVDP lawyers who specialize in this area of tax and law spend countless hours assessing client facts, to develop the best plan possible under the client’s specific circumstances. That is why you need an attorney with extensive experience, and a strong background in litigation and trial work.
Just working in a non-legal role for the IRS or an accounting or finance firm provides no experience to draw from when it comes to handling offshore voluntary disclosure. These smaller, less-experienced firms are notorious for submitting willful clients into the streamlined program to make a quick buck off the consumer.
Don’t be misled by inexperienced counsel.
We inherit these types of cases all the time:
Is the Attorney a Board-Certified Tax Law Specialist?
The Board-Certified Tax Law Specialist credential is the top credential in tax law. Most highly-experienced OVDP lawyers will have earned this credential. It is earned by less than 1% of attorneys nationwide. The test is offered in many states, such as California, Texas, Florida, Arizona and more.
Since IRS tax law is federal law (a practitioner must only be licensed as an attorney in one state to practice federal tax law) and the credential is so coveted — many attorneys will seek out licensure in another state that offers the exam, just so they can sit for the exam, and become a board-certified specialist (the exam requires significant tax experience, education and recommendations from attorneys and judges).
*The credential requires several continuing education classes in tax law every 3-years.
Has the OVDP Lawyer earned an Advanced Tax Law Degree?
If you are researching OVDP lawyers, you will come across many different acronyms – enough of them to make your head spin. But, one of the most important acronyms is called an LL.M. or a “Master’s in Tax Law.” Tax Law is incredibly complex and continues to evolve. Therefore your attorney should have this advanced credential.
Is the Attorney Dually-Licensed in Law and Tax?
When it comes to offshore voluntary disclosure, the submission contains both tax and legal components. The most experienced attorneys in this area of law are dually-licensed as either an Attorney/Enrolled Agent, or Attorney/CPA. This helps to secure the attorney-client privilege and serves to protect the client confidentiality, which can easily be broken when the attorney relies upon Kovel.
While not all CPAs practice in tax, the EA credential focuses exclusively in tax.
It requires 72 hours of continuing education courses every 3-years.
How Many Offshore Disclosures Has the Attorney Prepared?
This is a crucial question.
They say it takes 10,000 hours to master a skill. We will tell you, NO ONE ever masters tax law. But, if your attorney has handled several hundred streamlined cases and offshore voluntary disclosure program submissions, you will be in good hands. When pressed, if the OVDP lawyers you are interviewing respond to this question with a “a good amount,” “a few dozen,” or “many” – but refuse to provide you a solid number or range – it means they are probably not as experienced as they want you to believe.
Golding & Golding: About our Firm
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
*Beware of less experienced copycat firms misleading the public about the streamlined procedures and IRS offshore disclosure.
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+.
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
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.