Once you make the decision to submit to the IRS Streamlined Program, the next step is retaining effective and experienced representation for your Streamlined Disclosure legal and tax journey.

On many occasions, clients have asked us to provide a bit of guidance to other individuals considering the program, on how to select counsel — so that other applicants can avoid some of the same past mistakes and pitfalls these other clients experienced, before finding us.

How to Hire a Streamlined Procedure Lawyer

First and foremost, you should hire a specialist. Streamlined & Offshore Disclosures are a specialized area of tax law.

For example, at Golding & Golding we specialize exclusively in IRS offshore voluntary disclosure.  And, while we are not the only game in town, we have successfully submitted more than 1000 offshore disclosure applications, including OVDP, VDP, Streamlined Procedures, Reasonable Cause and more.

We are the “go-to” firm for other Attorneys, CPAs, Enrolled Agents, Accountants, and Financial Professionals across the globe, and have seen many clients come our way, after having first retained less-experienced counsel who sold them on a false bill of goods.

Taking Over Other Firm Cases

Several times each year, we are contacted by clients who had already retained another attorney, that over-sold and underperformed when it came to their streamlined program submission. 

Here are two examples of cases we recently took over:

5 Simple Hiring Tips for Streamlined Filing Lawyers

Here are a few simple tips, traps and pitfalls to be aware of:

Advanced Degrees, Experience & Credentials 

Each and every streamlined procedure case is complex. By submitting to the streamlined program, you are making an affirmative representation to the IRS, under penalty of perjury — which is a big deal.

The submissions require that the attorney and his or her team representing you have extensive tax and legal experience.

In addition to many years of tax experience, specialists will also have advanced degrees and credentials. This is because the additional education (and ongoing “Continuing Education” requirements) significantly helps to continually expand the attorney’s knowledge base of complex tax issues.

The additional tax knowledge greatly benefits the lawyer (and client) in all aspects of Streamlined Disclosures.

Attorneys without the additional advanced tax education will oftentimes miss these issues.

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 of Attorney law firm experience as a practicing attorney
  • Extensive litigation, high-stakes audit and trial experience

Flat-Fee, Full-Service (Tax and Legal)

Experienced Streamlined Filing firms handle both the entire tax and legal matter in-house.

Not only does it provide the client added protection, but it allows the firm to offer a flat-fee, full-service for both and legal — along with any additional follow-up with the IRS and audit/examination that may stem from a streamline disclosure.

When a firm uses an outside CPA, the individual is at the mercy of the outside CPA’s billing rates, scheduling, etc.

Most CPAs charge their own rates in addition to what the attorney charges you. And, if the client (you) is then audited — those fees may skyrocket.

Attorneys who Set Time Allocated to Prepare the Application

How come experienced specialists do not provide estimates for the time it takes to prepare a Streamlined submission?

Because experienced specialists do not treat Streamlined submissions as an “assembly line” or “routine.” Each case is unique, and each case comes with its own set of facts and circumstances; it is impossible to determine from the outset how many hours a project will take.

Oftentimes, the most complicated and complex tax aspects of the submission are either hidden in plain-sight, or buried far below the surface. It takes significant time to properly analyze a client’s facts and circumstances.

We know, because when a case comes to us after it was handled by a less-experienced firm, we find that these attorneys usually missed several complex issues that they simply did not spot — because they do not have the knowledge or experience to spot them.

*The one thing you can take away from the fact that the firm is telling you much time they will spend on the case, is that they will not spend any additional time on your submission than they allocated — even if your case requires it.

Kovel Protection

A Kovel Agreement is used in very rare circumstances, in which an attorney utilizes an outside accountant/forensic accountant in highly complex accounting scenarios which will impact tax liability (usually involving foreign business and a multi-jurisdictional reconciliation(s).

Kovel letters never attach to tax return or preparation, and can be rejected by the courts.

If a firm sends you out to another CPA instead of handling the matter in-house, they are unnecessarily putting your confidentiality risk.


Because if a client speaks with an outside CPA about legal issues (which is very common) the privilege may be lost. By containing the matter to in-house tax and legal preparation, these  issues are avoided.

Experienced counsel limit the use of Kovel, and do not use it for tax preparation.

Going Streamlined When You are Willful

If you were willful, unfortunately neither the streamline program nor reasonable cause is an option. It doesn’t matter if it was just a small amount of money or not. (There is an updated OVDP/VDP process, which actually benefits some clients more than the Streamlined Procedures do.)

IRS Risk of Punishment

Despite this stern warning from the IRS that if a willful person goes streamlined they may be prosecuted, some attorneys are still willing to take you streamlined.


– They have not handled litigation/trial and cannot appreciate the risk they are putting the client in.

– They “artificially” reduce the fees for the client, and jeopardize the client’s freedom.

– They are not experienced enough to take the client through a full voluntary disclosure submission (VDP). In fact, some of these attorneys do not even practice in voluntary disclosure outside of streamline cases, which they treat as an “assembly line type of case”

*Here is a case study example of what happens when you’re willful, but convince to go streamlined.

Streamlined Filing Lawyers – Golding & Golding, A PLC

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.

Interested in Filing under IRS Streamlined 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.