California Streamlined Offshore Disclosure Specialist
The California International Tax Lawyers at Golding & Golding specialize exclusively in Offshore Disclosure Programs, such as the Streamlined Offshore Voluntary Disclosure Programs (Domestic and Foreign) and VDP (Voluntary Disclosure Program). Unlike other law firms that advertise as experts — but seem lost and confused when asked about the specifics of these programs — wandering aimlessly in the streets of offshore disclosure and trying to grasp the complexity of IRS international tax law — we limit our representation to matters involving offshore disclosure and compliance. And, due to the complexity of international tax law, California residents (along with anybody seeking to enter the streamline procedures) should retain an attorney that is Board-Certified — and represents clients with a flat-fee, full-service model for tax and legal. Whether a taxpayer resides in San Diego County, Orange County, Los Angeles County, San Jose, or San Francisco – the International Tax Law Offices of Golding & Golding will safely get you into compliance. For information about offshore disclosure and the streamlined program, please visit our free video library with hundreds of videos on international tax matters to choose from.
California Streamlined Offshore Disclosure Tax Representation
Within the world of offshore disclosure and tax compliance, our international tax attorney team specializes exclusively in offshore tax and compliance matters, matters such as:
Here is a brief summary of some of the key international tax Compliance matters that we offer representation for:
Offshore Voluntary Disclosure & Tax Amnesty
When a US person has unreported foreign accounts, assets, investments, and/or income there may be a risk for IRS fines and penalties. The penalties can be rough, but they can oftentimes be avoided or minimized by using one of the approved offshore tax amnesty and voluntary disclosure programs that can safely get you into compliance. *Be careful with some of the fear-mongering you will undoubtedly come across during your Google research expedition.
FATCA & FBAR
FBAR & FATCA are two mainstays for aggressive IRS enforcement and can be resolved by our California Streamlined Offshore Lawyers. FBAR refers to Foreign Bank And Financial Account Reporting. The technical name of the form is FinCEN Form 114. FATCA on the other hand refers to the Foreign Account Tax Compliance Act. When a Taxpayer has a FATCA reporting requirement, they are typically required to file a Form 8938 to report their FATCA Specified Foreign Financial Assets. The US government and IRS specifically have made enforcement a key priority.
If you receive a FATCA Letter or CRS (Common Reporting Standard) Letter — sometimes referred to as a Know Your Customer letter — the clock has started ticking for the foreign bank to report you to the IRS — and you should consult with experienced counsel.
Reporting Gifts from Foreign Persons
When a US person receives a gift from a foreign person that meets the threshold for reporting on form 3520, but they do not timely file the form — the IRS may issue penalties. Since it generally takes the taxpayers some time to realize they should have filed the form, they oftentimes get hit with the maximum penalty — which is 25% of the value of the gift.
Foreign Trust Reporting
Foreign trusts have to be reported on Forms 3520 and 3520-A. The tax and reporting requirements for foreign trusts can be very onerous and complicated.
Filing Foreign Corporation & Partnership Information Returns
When a US person has an ownership or interest in a foreign corporation or foreign partnership, they may have several reporting and filing requirements. Two of the most common forms the taxpayer may have to file are form 5471 or form 8865. If the taxpayer does not file these forms timely, they may be subject to fines and penalties.
Reporting Foreign Pension
The rules surrounding the US reporting and taxation of foreign pensions are very complicated. Whether or not the foreign country has entered into a tax treaty with the United States (such as the UK) will help determine the US taxation rules for the pension. The problem is that not all tax treaties go into great depth regarding specific foreign pensions — such as Australia and the superannuation tax and reporting rules. Likewise, with some foreign countries, the US has not entered into any tax treaty with them, and therefore the income generated from these types of retirement plans — such as provident funds — from countries such as Singapore and Hong Kong may be taxable in the US (even though they are tax-deferred overseas).
Avoiding or Minimizing Offshore Penalties
Sometimes a taxpayer will receive a notice such as a CP15 notice, 504 Notice, or examination/audit request regarding international-related penalties. Our International Tax Attorneys work with clients to try to get these penalties minimized, avoided, or abated.
Foreign and International Cryptocurrency Tax and Reporting
The US government has yet to issue specific rules regarding the tax and reporting of overseas cryptocurrencies located outside of the United States.
As recent as December 2020, FinCEN has released proposed regulations for overseas cryptocurrency which tends to mimic the regulations required for similar cash transactions to avoid structuring and smurfing.
Expatriation for Legal Permanent Residents and Citizens
When it is time for a legal permanent resident to abandon their status or a US citizen to renounce their citizenship, they will enter the world of the IRS expatriation rules, US exit tax, and the dreaded covered expatriate analysis. This is a very complicated area of tax law. Our International Tax Attorneys have worked with many clients facing expatriation and offshore compliance and have developed strategies to help safely get them out of the U.S. tax system.
In conclusion, the international tax attorney team at Golding and Golding specializes exclusively in offshore tax compliance and reporting. We have represented thousands of clients nationwide and in over 80 countries with safely getting into offshore tax and reporting compliance.
About Our California Streamlined Offshore Disclosure Tax & Law Firm
The Golding & Golding California Offshore Disclosure Tax and Law Firm specializes exclusively in international tax, and specifically IRS disclosure & compliance.
Contact our firm today for assistance.