201911.09
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Reasonable Cause Statement for Offshore Disclosure

Reasonable Cause Statement for Offshore Disclosure: When a person is out of compliance for undisclosed foreign and offshore assets, accounts, investments and income, a person is considered “non-compliant.” While the IRS offers various amnesty programs, unless a person qualifies under the strict definition of a non-resident, and can show non-willfulness — they are almost always subject to a penalty.

Some clients feel (understandably so) that any penalty is unfair. Instead of submitting under traditional amnesty programs, they submit a Reasonable Cause package to the IRS.

Reasonable Cause is a complex submission. There are no forms or templates available

IRS Offshore Voluntary Disclosure Specialist

IRS Offshore Voluntary Disclosure Specialist

Golding & Golding: Our international tax lawyers practice exclusively in the area of IRS Offshore & Voluntary Disclosure. We represent clients in 70+ different countries. Managing Partner Sean M. Golding is a Board-Certified Tax Law Specialist Attorney (a designation earned by < 1% of attorneys nationwide.). He leads a full-service offshore disclosure & tax law firm. Sean and his team have represented thousands of clients nationwide & worldwide in all aspects of IRS offshore & voluntary disclosure and compliance during his 20-year career as an Attorney.

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.
IRS Offshore Voluntary Disclosure Specialist