- 1 Referred to an Outside CPA
- 2 Researching Streamlined & Voluntary Disclosure
- 3 General Practice Tax Lawyers
- 4 Danger of Referring Clients to an Outside CPA
- 5 Streamlined Disclosure Tax Attorney – Golding & Golding
- 6 Recent Golding & Golding Case Highlights
- 7 How to Hire Experienced Streamlined Counsel?
- 8 Interested in Learning More about Golding & Golding?
Did Your Streamlined Tax Attorney Refer You to a CPA?Did Your Streamlined Tax Attorney Refer You to a CPA?
There has been a surge in recent enforcement activities for IRS international tax and offshore reporting related issues. Oftentimes, these issues involve the non-reporting of foreign accounts, investments, assets, and income. At Golding & Golding, we have received many inquiries in the past few months about clients stuck in what seems like an impossible situation.
These situations could have been avoided, had the client retained experienced counsel and not been sold a false bill of goods.
Referred to an Outside CPA
In a recent case we were referred, a client first retained a sole practitioner, since the attorney falsely represented how offshore disclosure works and artificially reduced the fee.
The attorney is not licensed as an EA or CPA, does not have a master’s of tax law, and treats the cases as an “assembly line,” only allocating a 5-10 hours to each case – not matter how complicated.
The attorney referred the client to a pre-selected outside a CPA. The client did not have the opportunity to meet the CPA before retaining.
The attorney did not accompany the client to the CPA. The client then ended up getting comfortable with the CPA (since the CPA was handling the majority of the work).
During the communications with the CPA, the client began discussing issues about willfulness, and trying to get a second opinion about the attorney, This was because the attorney did not accompany the client to the CPA), and her further research led her back to the same 3 or 4 dually-licensed Attorneys.
Now the client is being audited, and all the legal communications the client had with the CPA may be discoverable by the IRS.
Researching Streamlined & Voluntary Disclosure
Here is the typical situation we see often: A client researches offshore disclosure. They located a few experienced dually-licensed Attorney/EA and Attorney/CPA firms. These experienced tax practitioners have advanced degrees such as an LL.M. (Master’s in Tax), advanced experienced, and usually a Board-Certification — they have been around the block.
The attorneys have have litigation and trial experience, and want to protect the client. These attorneys explain to the client the serious nature of the submission.
Even a streamlined disclosure is submitted under penalty of perjury.
If a client is caught lying in their statement, they can be in serious trouble. In addition, these attorneys explain the serious nature of “willfulness,” and how to properly understand the issues.
General Practice Tax Lawyers
These are attorneys who are not specialized in Offshore Disclosure. They author articles and downplay the serious nature of the Streamlined Program.
These attorneys typically:
- Do not have an LL.M. or Master’s in Tax
- Are not Board-Certified
- Do not have an EA or CPA license
- Do not have trial or litigation experience
- Handle more than just Offshore Disclosure
These attorneys embellish their prior experience, such as “working for the IRS,” and treat your submission as an assembly line case. They allocate a few hours to your case (5-10 hours), and do not handle the tax portion of the submission.
They refer you out to an outside CPA under “Kovel,” but fail to explain to the client that Kovel is limited, and my be rejected by the courts.
Danger of Referring Clients to an Outside CPA
Experienced Offshore Disclosure specialists are dually-licensed in Tax and Law. They handle the entire submission “in-house,” to avoid attorney-client privilege issues on legal related issues.
Streamlined Disclosure Tax Attorney – Golding & Golding
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+.
How to Hire Experienced Streamlined 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.
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.