- 1 Streamlined Offshore Procedures Lawyer
- 2 Flat-Fee,Full-Service Streamlined Offshore Tax & Law Team
- 3 Tax Prep & Attorney-Client Confidentiality (U.S. v. Abrahams)
- 4 Attorney-Client Privilege in Streamlined Cases
- 5 How to Hire Experienced Streamlined Offshore Counsel
- 6 Why is Using an Outside CPA Dangerous?
- 7 We Specialize in Streamlined & Offshore Voluntary Disclosure
Streamlined Offshore Procedures Lawyer
Streamlined Offshore Procedures Lawyer & Fees: Are you interviewing Streamlined Filing Lawyers about their representation & fees? Our Streamlined Filing Lawyers have developed a highly-effective representation fee model that is used by other experienced law firms across the globe. At Golding & Golding, our Attorneys specialize exclusively in Streamlined Filing and offshore compliance. Our attorneys have been featured in Forbes, LexBlog, HG, NOLO, and more.
We will summarize how Streamlined Filing Lawyer Fees for Foreign Account reporting.
Flat-Fee,Full-Service Streamlined Offshore Tax & Law Team
The tax and legal portions of a Streamlined Offshore Filing should always be handled in-house by the Attorney Tax Specialist and their in-house tax team.
The entire matter from beginning-to-end should be flat-fee, full-service, and all-inclusive, including client follow-up, IRS follow-up and audit/examination defense.
Each client has a unique story, with their own specific facts and circumstances.
No two streamlined cases are the same, and fees should be representative of that specific client’s case.
Fees should only be determined after the Attorney has spoken in detail with the client — and not some prefabricated fee.
Tax Prep & Attorney-Client Confidentiality (U.S. v. Abrahams)
In Abrahams, the Attorney also handled Tax Preparation for his clients.
“Abrahams is an attorney who prepares income tax returns for his clients, and also represents many of them in disputes with the Internal Revenue Service before the Tax and Claims Courts.
The IRS wanted lots of his documents.
“The summons demanded that Abrahams produce “[a]ll documents relating to the preparation to income tax returns for others for [1978 to 1984],” and included a nonexclusive list of six categories of materials.
Abrahams’ protestations at a hearing before the district court exposed two ambiguities in the language of the summons. First, if “relating to” is read very liberally, the summons covers all the material for Abrahams’ Tax and Claims Court litigation, since these cases “relate to” what was claimed on clients’ tax returns.”
The Attorney Claimed Privilege, and the IRS disagreed.
“Abrahams asserted below that all the information demanded by the IRS was protected against disclosure by the attorney-client privilege. The government claimed that none of it was.”
Court Held Legal Communications could be protected.
“For its part, the IRS argues that the questionnaires information is automatically unprotected because the clients completed the questionnaires in order to allow Abrahams to prop rare their returns.
We cannot fully accept that contention. Although communications made solely for tax return preparation are not privileged, communications made to acquire legal advice about what to claim on tax returns may be privileged.”
Attorney-Client Privilege in Streamlined Cases
In applying this methodology to offshore disclosure (as is the approach by nearly all firms that specialize in Streamlined and Offshore Disclosure), the client would have a much stronger position to have an attorney and their team handle the matter in-house, than to be shipped out to some outside CPA or EA where there is definitely no attorney-client privilege, save for a possible (and much narrower) Kovel protection on very limited issues — assuming Kovel was not rejected.
How to Hire Experienced Streamlined Offshore Counsel
Generally, experienced attorneys in this field will have the following credentials/experience:
- 20-years experience as a practicing attorney
- Extensive litigation, high-stakes audit and trial experience
- Board Certified Tax Law Specialist credential
- Master’s of Tax Law (LL.M.)
- Dually Licensed as an EA (Enrolled Agent) or CPA
Why is Using an Outside CPA Dangerous?
The reason an outside referral is dangerous, is because if the client discusses any legal issues about their offshore streamlined case to the outside CPA (and it is nearly impossible not to), they risk losing the confidentiality and protection of the attorney-client privilege.
This is compounded tenfold when the client faces a subsequent IRS Audit, and the IRS wants to speak with the CPA about the issues discussed between the client and the outside CPA — which the IRS has every right to do.
Have You Been Contacted by the IRS?
At some point in the process during or after the streamlined submission, the client realizes they discussed legal matters with the CPA, and now their confidentiality and attorney-client privilege is at serious risk.
When these clients contact us, they feel lost and duped.
They had no say in which CPA the Attorney chose, and overall had a horrible experience with the CPA that the attorney selected for them.
We Specialize in Streamlined & Offshore Voluntary Disclosure
Our firm specializes exclusively in international tax, and specifically IRS offshore disclosure.
We are the “go-to” firm for other Attorneys, CPAs, Enrolled Agents, Accountants, and Financial Professionals across the globe. Our attorneys have worked with thousands of clients on offshore disclosure matters, including FATCA & FBAR.
Each case is led by a Board-Certified Tax Law Specialist with 20-years experience, and the entire matter (tax and legal) is handled by our team, in-house.
*Please beware of copycat tax and law firms misleading the public about their credentials and experience.
Less than 1% of Tax Attorneys Nationwide Are Certified Specialists
Our lead attorney is one of less than 350 Attorneys (out of more than 200,000 practicing California Attorneys) to earn the Certified Tax Law Specialist credential. The credential is awarded to less than 1% of Attorneys.
Recent Case Highlights
- We represented a client in an 8-figure disclosure that spanned 7 countries.
- We represented a high-net-worth client to facilitate a complex expatriation with offshore disclosure.
- We represented an overseas family with bringing multiple businesses & personal investments into U.S. tax and offshore compliance.
- We took over a case from a small firm that unsuccessfully submitted multiple clients to IRS Offshore Disclosure.
- We successfully completed several recent disclosures for clients with assets ranging from $50,000 – $7,000,000+.
Interested in Learning More about our Firm?
No matter where in the world you reside, our international tax team can get you IRS offshore compliant.
We specialize in FBAR and FATCA. Contact our firm today for assistance with getting compliant.