The International Tax Law Blog: Articles, News & Tax Resources

Flat-Fee or Hourly Streamlined Offshore Filing Lawyer?

Contents1 Flat-Fee Streamlined Filing Lawyers2 Low Up-Front Hourly Fee Bait-and-Switch for Streamlined Cases3 Benefits of Flat-Fee Streamlined Filing Lawyers4 International Tax Lawyer Specialist Team: Golding & Golding Flat-Fee Streamlined Filing Lawyers Flat-Fee Streamlined Filing Lawyer Fees: With the IRS having both closed OVDP (2018) and […]

IRS Voluntary Disclosure Program Explained: New OVDP 2023

Contents1 New IRS Voluntary Disclosure Program & OVDP Updated2 2020 IRS Voluntary Disclosure Program3 No IRS Voluntary Disclosure Program Placeholders4 Tax Treatment under IRS Voluntary Disclosure5 IRS Voluntary Disclosure Program Offshore Penalties 6 Streamlined or Voluntary Disclosure 7 What are the Fees for Hiring an Offshore Disclosure […]

Delinquent FBAR Submission Procedures to IRS (New) 2023

Contents1 Delinquent FBAR Late-Filing Submission Procedures2 Delinquent FBAR Submission Procedures (DFSP)3 Delinquent International Information Return Submission Procedures (DIIRSP) 4 Streamlined Domestic Offshore Procedures (SDOP)5 Streamlined Foreign Offshore Procedures (SFOP)6 IRS Voluntary Disclosure Program (VDP) for Delinquent FBAR & FATCA7 Reasonable Cause for Delinquent FBAR and FATCA8 Golding […]

The (New) Streamlined Filing Compliance Procedures 2023

Contents1 Streamlined Filing Compliance Procedures 2 Purpose of the IRS Streamlined Filing Compliance Procedures3 Who is Eligible for the Streamlined Procedures4 What are the Fees for Hiring a Streamlined Filing Offshore Attorney?5 About Our International Tax Law Firm Streamlined Filing Compliance Procedures In order to […]

Streamlined Domestic Offshore Procedures: (New) 2023

Contents1 IRS Streamlined Domestic Offshore Procedures (SDOP)2 Eligibility for Streamlined Domestic Offshore Procedures3 How to Submit to Streamlined Domestic Offshore Procedures4 3-Years of Amended Tax Returns 5 6-Years of FBAR Filing6 Pay a Title 26 Miscellaneous Offshore Penalty7 What are the Fees for Hiring a Streamlined Domestic […]

Streamlined Foreign Offshore Procedures: (New) IRS 2023

Contents1 IRS Streamlined Foreign Offshore Procedures (SFOP)2 Eligibility for Streamlined Foreign Offshore3 How to Submit to Streamlined Foreign Offshore Procedures4 Title 26 Miscellaneous Offshore Penalty WAIVED5 What are the Fees for Hiring a Streamlined Foreign Offshore Attorney?6 We Specialize in Streamlined Disclosure and Offshore Compliance […]

The Form 3520 Penalties and Abatement Procedure Explained

Contents1 Form 3520 Penalties and Abatement Procedure2 Late Filed Form 3520 Penalties & the IRS3 CP15 Notice of Form 3520 (6039F) Penalty4 The Attorney Files the Initial Protest5 Form 3520 Reasonable Cause Letter Rejected LTR 854C6 Would an Appeals Conference Prevent a CDP?7 Beware that CDP […]

Foreign Pension Account Reporting on IRS International Forms (New) 2022

Contents1 Is Foreign Pension Reported on FBAR, Form 8938, 8621 & 3520-A?2 Who is Considered a US Person for Foreign Pension Reporting?3 Treaties are Mainly for Tax, Not Reporting 4 International Reporting Form Requirements for Foreign Pension5 FBAR & Foreign Pension Plans6 Form 8938 (FATCA) & Foreign […]

FBAR Penalties: What if You Missed Filing International Forms 2023

Contents1 FBAR Penalties (Update)2 Court Ruling is Limited to Civil Non-Willful FBAR Penalties3 Non-Willful Civil FBAR Penalties4 Willful Civil FBAR Penalties5 Willfulness is not the same as ‘Intent’6 Criminal FBAR Penalties7 Current Year vs Prior Year Non-Compliance8 Avoid False Offshore Disclosure Submissions (Willful vs Non-Willful)9 Golding […]

The Form 8938 Foreign Asset Reporting Requirements (New) 2023

Contents1 Form 8938 2 Threshold Filing Requirements for Form 89383 Form 8938 Threshold Filing Requirements4 Foreign Financial Asset Definition 5 8938 Form Filing Deadline6 Late Filing Form 8938 Penalties7 Reasonable Cause Exception to Late Filing8 Golding & Golding: About Our International Tax Law Firm Form 8938 Form […]