IRS Offshore Disclosure Areas of Practice (Golding & Golding) Golding & Golding, Certified Tax Specialist Lawyer

IRS Offshore Disclosure Areas of Practice (Golding & Golding) Golding & Golding, Certified Tax Specialist Lawyer

IRS Offshore Disclosure Areas of Practice (Golding & Golding Tax Law)

Golding & Golding is a flat-fee, full-service firm; we are lawyers who assist international clients with reporting and disclosing prior year, unreported accounts, assets, investments and income to the IRS. 

We Specialize in Offshore  Disclosure

We are the IRS Offshore Disclosure Attorneys that other Attorneys, CPAs, Tax Practitioners (and even IRS personnel) contact when they need IRS Offshore Disclosure representation.

*We are the only State Bar Board Certified Tax Law Firm that specializes exclusively in IRS Offshore Disclosure Law.

Areas of Practice

IRS Offshore Disclosure is a complex area of law, and may involve many aspects of disclosure, including:

Unfiled Tax Returns

Filing multiple year of unfiled & delinquent prior year tax returns.

Reporting Foreign Income & Assets

Evaluate and report various types of foreign income and income source

FBAR (FinCen 114)

Reporting Foreign Bank and Financial Accounts to the IRS. 

Form 8938 (FATCA)

Foreign Account Tax and Compliance Act reporting of Specified Foreign Financial Assets and Income to the IRS. 

Form 3520 (Foreign Gift & Inheritance)

Represent clients to report previously undisclosed gifts or inheritance from a foreign person.

Form 5471 (Foreign Corporation)

Represent clients to report previously undisclosed interest/ownership in a foreign corporation.

Form 8621 (Foreign Investment Company)

Represent clients to report previously undisclosed interest/ownership in a Passive Foreign Investment Company.

Form 8865 (Foreign Partnership)

Represent clients to report previously undisclosed interest/ownership in a Foreign Partnership.

Form 3520A (Foreign Trusts)

Represent clients to report previously undisclosed interest/ownership in a Foreign Trust

Foreign Mutual Funds

Evaluate and report Foreign Mutual Funds to determine PFIC Reporting and Excess Distribution.

Foreign Life Insurance

Evaluate and report Foreign Life Insurance Policies to determine Surrender Value, Income Growth, Excise Tax.

Fixing Quiet Disclosures

Represent clients who previously submitted a Quiet Disclosure to avoid willful penalties and an IRS Criminal Investigation, and work to reduce taxes, fines and penalties.

PFIC

Evaluate and report client investments.

Foreign Real Estate Income

Evaluate and report client foreign rental income, including properly claiming credits.

Foreign Real Estate Sales

Evaluate and report client sale of foreign property.

Subpart F Income/GILTI

Evaluate and report client Subpart F Income and GILTI.

Foreign Pension & Retirement

Evaluate and report foreign pension and retirement.

International Special Agent Investigations

Evaluate and asses potential willful and criminal tax liability.

International Cryptocurrency 

Evaluate and asses issues involving Cryptocurrency Tax and Reporting.

Offshore Voluntary Disclosure Program (OVDP)

OVDP is an acronym for Offshore Voluntary Disclosure Program. It is the traditional Internal Revenue Service program designed to bring individuals, estates, and businesses into Offshore and Foreign Compliance.

*Currently discontinued as of 9/28/2018

Streamlined Domestic Offshore Procedures (SDOP)

If you have unreported Foreign Accounts, Income, Investments or Assets and want to get into IRS compliance, the Streamlined Domestic Offshore Procedures (SDOP) 

Streamlined Foreign Offshore Procedures (SFOP)

If you reside overseas and have unreported Foreign Accounts, Income, Investments or Assets and want to get into IRS compliance, the Streamlined Domestic Offshore Procedures (SDOP) may be a good option for you. 

Reasonable Cause Statement

For some taxpayers who were non-willful in failing to comply with IRS and DOT rules for Reporting Foreign Accounts, Foreign Income, Foreign Assets, and Foreign Property, submitting a Reasonable Cause Statement in lieu of Amnesty. 

Traditional IRS Voluntary Disclosure Program

The traditional IRS Voluntary Disclosure Program is used in lieu of OVDP or the Streamlined Programs.

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