Tax Havens & IRS Offshore Voluntary Disclosure: Are you at Risk?
Tax Havens & IRS Offshore Voluntary Disclosure: Are you at Risk? In recent years, the IRS has continued it’s aggressive enforcement of foreign accounts compliance. The enforcement is amplified when a person has money overseas in a tax haven country. When a person has unreported offshore income, accounts, assets and/or investments, they may qualify for one of the various IRS Offshore Voluntary Programs, such as traditional voluntary disclosure, streamlined filing, or delinquency procedures. Each program has its own set of rules and requirements, with the main issue being whether the applicant is willful vs. non-willful.
A tax haven is generally a foreign country which is used to hide money from the United States. Ever since the introduction of FATCA (Foreign Account Tax Compliance Act) and reinvigorated enforcement of FBAR Reporting – it has become much harder for us persons to hide money in a tax haven country.
Switzerland as a Tax Haven
For example, in Switzerland – which was previously hailed as one of the top tax havens in the world – various foreign financial institutions entered into deferred prosecution agreement with the U.S. government. In addition, Swiss financial institutions have provided governments across the globe with more than 3.1 million Account holder names and other identifying information.
Panama as a Tax Haven
Another recent example was in Panama and the “Panama Papers.” At the time, a whistleblower outed several Financial institutions and participants with developing strategies to illegally avoid U.S. taxes for their clients.
IRS Offshore Voluntary Disclosure
IRS offshore voluntary disclosure is used as a way to avoid incredibly harsh fines and penalties that may accompany noncompliance. While the Internal Revenue Service discontinue OVDP, they also expanded the traditional voluntary disclosure program. Therefore, whether a person was willful or non-willful — they will still have the opportunity to enter into one of the amnesty programs and reduce, minimize, and sometimes avoid any penalties.
Learn more about the services we offer.
Golding & Golding, Board-Certified Tax Law Specialist
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.
Don’t be misled by inexperienced counsel.
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.
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.