Who we Are?

We have helped 1000s of clients nationwide and in over 75+ different countries. Our Offshore Specialist team is passionate about bringing clients into compliance. We want to help you understand the basics of these programs without being  misled by inexperienced counsel, or being sold a false bill of goods from attorneys who are not  dually-licensed in Law and Tax. These attorneys intentionally misapply the principles of  Kovel, and  attorney-client confidentiality, to the detriment of the client. At our firm, each case is led by a  Board-Certified Tax law Specialist with experience in high-stakes offshore tax matters. Meet the partners.

Why We Specialize?

A large portion of our International tax law practice is dedicated to representing clients in the Streamlined Filing Compliance Procedures (domestic and foreign). We represent clients nationwide and across the globe in over 75+ countries. While our main website blog and attorney articles have been featured on NOLO, HG, Forbes, and more, we wanted to provide a specific website devoted exclusively to IRS Streamlined Compliance Filing for clients who may get overwhelmed by all the international tax information on our main site.

Do I Qualify?

Each of the different IRS streamlined programs have different requirements for submission. But, no matter which program you apply for — there are two main requirements. The first requirement is that you are not currently under audit. The second requirement is that you were non-willful. The IRS has not developed a bright-line test for non-willfulness, and it essentially boils down to a totality of the circumstances test. We provide clients, CPAs, EAs, and other Attorneys across the globe with safe and effective representation.

Streamlined Domestic for U.S. Residents

When a person is a U.S. resident, or does not otherwise meet the technical requirements for being an IRS Foreign Resident, they will submit to the  Streamlined Domestic Offshore Procedures. There are various requirements for submission, but one important requirement is that the filer had already filed their original tax returns (timely). In other words, the IRS does not permit you to file original tax returns under the Streamlined Domestic Procedures.

Streamlined Foreign for Non-U.S. Residents

When a person is a non-U.S. resident, and qualifies as a Foreign Resident under the strict IRS rules, they will submit to the  Streamlined Foreign Offshore Procedures. This qualifies the applicant for a waiver of the  Title 26 Miscellaneous Offshore Streamlined Penalty. In addition, the applicant may file original tax returns in the foreign version of the streamlined program. The penalty waiver makes this program a great option for non-willful taxpayers who are not under audit.

What Type of Attorney to Hire?

Generally, it helps if you hire an attorney, since only with an attorney do you receive the attorney-client privilege. Your attorney should have the following credentials.

– 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

Recent Case Highlights

– Represented a client in an 8-figure disclosure that spanned 7 countries.

– Represented a high-net-worth client with expatriation & offshore disclosure.

– Represented an overseas family with bringing multiple businesses & personal investments.

– Took over a case from a small firm that unsuccessfully submitted multiple clients to IRS.

– Successfully completed several disclosures for clients with assets $50,000 – $7,000,000+.

Offshore Disclosure Tax Blog

How to Avoid the IRS Asserting Multiple Non-Willful FBAR Penalties
IRS Assesses Multiple Non-Willful FBAR Penalties:  The IRS Assesses Multiple Non-Willful FBAR Penalties in some, but not all non-compliance tax situations. The Streamlined Program and Reasonable Cause are two effective methods for legally avoiding multiple non-willful FBAR penalties.  In recent years, the IRS has increased the […]
Form 5471 Delinquent Filing Penalty & Late Filing Abatement
Form 5471 Late Filing Penalty (2020): Delinquency & Abatement: The Form 5471 Late Filing Penalty can be pretty rough. And, since the IRS 5471 form is one of the most complicated International tax reporting forms required for taxpayers, it can can  all get pretty overwhelming for […]
Form 3520 Late Filing Penalty & Abatement
Form 3520 Late Filing Penalty: The Form 3520 Late Filing Penalty is extremely disproportionate to the “violation.” Sometimes (and oftentimes) it is simply a gift from a foreign parent to a U.S. person. The U.S. person is unaware that the gift must be reported to the […]
FATCA Insurance Policy Reporting on Form 8938
FATCA Insurance Policy Reporting on Form 8938: The FATCA Insurance Policy Reporting on Form 8938 requirements by the IRS for individuals can range from relatively straightforward, to the complex. FATCA is the Foreign Account Tax Compliance Act. Starting in 2012 when individuals file their 2011 tax […]
FBAR Penalty Cases (Recent Court Rulings for 2019-2020)
FBAR Cases: New Federal Court Rulings 2019:  The number of FBAR Cases and recent Federal Court Rulings on Foreign Bank Account Reporting matters is on the rise. The FBAR is the Foreign Bank and Financial Account Reporting Form. It is also referred to as FinCEN Form […]
H-1B FBAR Visa Rules & Disclosing Overseas Accounts 2020
H-1B Visa FBAR: Is it Mandatory to Report Offshore Accounts: The H-1B visa FBAR rules for disclosing overseas accounts are complex. That is because an H-1B visa Holder is not considered a U.S. Person in the same way that a U.S. Citizen or a Legal Permanent […]