International Tax Attorney Miami: Our international tax attorney and offshore disclosure team has been very successful in reducing, avoiding and abating offshore penalties for clients statewide. Golding & Golding represents clients in Miami, with IRSmatters involving Voluntary Disclosure and Streamlined Filing Compliance. We have helped numerous clients throughout Miami with penalties involving Form 3520, 3520-A, 5471, 8621, 8865 and 8938.Even though we are based in Irvine, California, we are often called upon to help clients nationwide and nationwide fix international and offshore tax issues by prior counsel on matters involving FBAR, FATCA and International Tax.The IRS has increased enforcement of foreign asset, account and income reporting compliance. The failure to timely and accurately report offshore money may result in significant fines and penalties, such as FBAR penalties. There have been several recent cases throughout the United States, including Illinois. Courts around the nation are split on issues involving FBAR penalties, foreign gifts, trusts & inheritances, and foreign corporations, partnerships and other entities.
Meet Golding & Golding
Many foreign taxpayers are overwhelmed by the US tax system — and we are here to help them safely get into foreign accounts compliance. The IRS does little to prepare new residents and investors with the specifics of what they are required to include on their tax returns, FBAR, Form 8938, etc. To aid clients in obtaining cost-effective representation, our International Tax Attorney Team has also developed an innovative flat-fee model that has been implemented by tax and law firms across the globe. The model is designed to handle both the tax and legal representation in-house, and help clients avoid the low upfront fee retainer bait and switch — and prevent inexperienced counsel’s misuse of Kovel.**A Kovel Letter does not apply to tax return preparation or legal communications surrounding the preparation — and it puts client confidentiality and privilege at serious risk when used incorrectly.
Areas of International Tax and Reporting
Within the world of offshore disclosure and tax compliance, our international tax attorney team specializes exclusively in offshore tax and compliance matters. 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 on of the approved offshore tax amnesty and voluntary disclosure programs that can safely get you into compliance.
FATCA & FBAR
FBAR & FATCA are two mainstays for aggressive IRS enforcement.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 aFATCA Letteror 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 is a 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 India, 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 ofoverseas cryptocurrencylocated outside of the United States.As recent as December 2020, FinCEN has released proposed regulationsfor overseas cryptocurrency which tends to mimic the regulations required for similar cash transactions to avoid structuring and smurfing.
Fees for Hiring an International Miami Tax & Legal Team
Learn why experienced Offshore Disclosure teams always chargeflat-fee for tax and legal representation — and avoid using Kovel Letters.
About Our Miami International Tax Attorney Team
Golding & Golding specializes exclusively in international tax, and specifically IRS disclosure & compliance.Contact our firmfor assistance.
Schedule a Confidential Reduced-Fee Initial Consultation with a Board-Certified Tax Attorney Specialist
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