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
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.