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Golding
Golding Board-Certified Tax Law Specialist
Golding & Golding, Board-Certified Tax Law Specialist
Board-Certified Tax Law Specialist
International Tax Lawyers

Latest from International Tax Blog

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Is a SICAV a PFIC Taxable and Reportable in the US? Is a SICAV a PFIC for IRS Filing Is a SICAV a PFIC for IRS Tax and Reporting: Depending on which country you maintain your foreign or offshore assets, one type of foreign investment you may have is referred to as a SICAV. A SICAV is a type of investment which is often seen in European countries. Technically, a SICAV is a société…
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Criminal Tax Willfulness What is Criminal Tax Willfulness Criminal Tax, Willfulness & Voluntary Disclosure: There is a common misconception about what the traditional voluntary disclosure program is used for in relation to willfulness. When it comes to civil violations, willfulness does not require deliberate or knowledge as it does in the criminal arena. For example, with FBAR Violations, willfulness may include Reckless Disregard (lacks actual intent) and Willful Blindness (lacks actual knowledge). When…
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Form 1040-C Departing Tax Return What is IRS Form 1040-C? IRS Form 1040-C: A common question we receive about expatriation involves the distinction between a Long-Term Resident (Green Card Holder 8 of the last 15 years), and a Visa Holder who has resided in the U.S. for a “long-Time.” In the former situation, a person may be deemed a covered expatriate and subject to exit tax. In the latter, the person is not a Long-Term…
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Emergency Offshore Tax Services Scam Beware of IRS Emergency Tax Scams Beware of Emergency Tax Help: We get it, tax law can be scary. Maybe it is because you received a notice from the IRS, or an IRS intent to issue a federal lien or levy. While tax law can be intimidating, 99% of the time it does not require emergency tax services by firms that will overcharge and underperform. Recent Example of Fear-Mongering…
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IRS Criminal Investigation IRS Criminal Investigation IRS Criminal Investigation: When the Internal Revenue Service believes you have committed a tax crime, they may launch a criminal investigation against you. Typically, the IRS Special Agents will be tasked with conducting the investigation into your background, finances, and tax history to assess the damage. In recent years, with the service making foreign accounts compliance a key enforcement priority, taxpayers who have not properly disclosed offshore accounts,…
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?   Minor Willful Offshore Tax Infraction: Can I Go Streamlined? Minor Willful Offshore Tax Infractions Minor Willful Offshore Tax Infractions: One of the biggest problems plaguing offshore tax law in 2020,  is that anyone can write anything they want on the internet – and publish it.  For the unsuspecting reader (read: you), the misinformation you find online can send you panicking down one rabbit hole and into the next. Unfortunately, this has become a…
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  International Tax Investigation International Tax Investigation International Tax Investigation: When a U.S. person has unreported income or undisclosed foreign accounts, assets or investments, they are at an increased risk of IRS fines and penalties. Over the last 10-15 years, the Internal Revenue Service has made foreign accounts compliance and key enforcement priority. With the introduction of FATCA (Foreign Account Tax Compliance Act) and renewed interest in the FBAR (Foreign Bank and Financial Account Reporting)…
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  What is Smurfing & Structuring? Difference Between Smurfing & Structuring Smurfing and Structuring: Financial Crimes comes in all shapes and sizes. When it comes to banking violations, it may include domestic issues, international issues or both. Oftentimes, financial crimes will overlap. Two of most common types of financial crimes are Smurfing and Structuring. While domestic crimes are bad, when these crimes involves offshore and international tax related matters, the penalties can be outrageous. And,…
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5 Myths About How Voluntary Disclosure Works 5 Myths About How Voluntary Disclosure Works 5  Myths About Offshore Voluntary Disclosure: There is a lot of bad information on the internet when it comes voluntary disclosure and the IRS. Many times, when clients contact us after conducting their research on Google, they are scared. This is compounded by the fact that the first few “free” initial consultations they have, tend to be aggressive and little…
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Court Affirms Incomplete Streamlined Procedure Willful FBAR Penalty New Streamlined Willful FBAR Court Analysis (US v Jones) Incomplete Streamlined Procedure Willful FBAR Penalty: In  the recent case of U.S. v Margaret Jones, the court affirmed an IRS Willful FBAR Penalty against an elderly widow, for a seemingly incomplete Streamlined Disclosure.  The catalyst for claiming that the Taxpayer’s submission was incomplete was because the applicant did not include a 5% streamlined penalty for her deceased husband. …