San Francisco Tax Lawyers, Counsel for Expats and Foreigners

San Francisco Tax Lawyer/Counsel for U.S. Expats and Residents

San Francisco Tax Lawyers

Our international tax law firm is the only tax law firm worldwide that specializes exclusively in offshore disclosure and expatriation and is led by a California board-certified tax law specialist. Each year, from our headquarters, we work with hundreds of different clients across the globe in over 80 countries on matters involving international tax. We represent numerous U.S. citizens, residents, and expats who either reside in San Francisco or use San Francisco as their base in all types of matters involving offshore disclosure and compliance. Unlike other tax law firms that handle numerous different types of tax law, we direct our entire focus and specialization on matters involving offshore disclosure and expatriation. Some of the common areas of international tax law that we specialize in include:

- - Late/Delinquent FBAR Reporting Amnesty
  - Late/Delinquent FATCA Reporting Amnesty
  - Late/Delinquent Form 5471 Reporting Amnesty
  - Late/Delinquent Form 3520/3520-A Reporting Amnesty
  - Late/Delinquent Form 8865 Reporting Amnesty
  - Late/Delinquent Form 5472 Reporting Amnesty
  - Streamlined Filing Compliance Procedures
  - Streamlined Domestic Offshore Procedures
  - Streamlined Foreign Offshore Procedures
  - IRS Voluntary Disclosure Program
  - Delinquency Procedures
  - Reasonable Cause
  - Penalty Abatement
  - Expatriation

Areas of International Tax and Reporting our Attorneys Practice

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 one of the approved offshore tax amnesty and voluntary disclosure programs that can safely get you into compliance. *Be careful with some of the fear-mongering you will undoubtedly come across during your Google research expedition.

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.

FATCA/CRS/KYC Letters

If you receive a FATCA Letter or 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 Singapore and Hong Kong may be taxable in the US (even though they are tax-deferred overseas).

Expatriation

When it is time for a legal permanent resident to abandon their status or a US citizen to renounce their citizenship, they will enter the world of the IRS expatriation rules, US exit tax, and the dreaded covered expatriate analysis. This is a very complicated area of tax law. Our International Tax Attorneys have worked with many clients facing expatriation and offshore compliance and have developed strategies to help safely get them out of the U.S. tax system. In conclusion, the international tax attorney team at Golding and Golding specializes exclusively in offshore tax compliance and reporting. We have represented thousands of clients nationwide and in over 80 countries by safely getting into offshore tax and reporting compliance.

Current Year vs Prior Year Non-Compliance

Once a taxpayer missed the tax and reporting (such as FBAR and FATCA) requirements for prior years, they will want to be careful before submitting their information to the IRS in the current year. That is because they may risk making a quiet disclosure if they just begin filing forward in the current year and/or mass filing previous year forms without doing so under one of the approved IRS offshore submission procedures. Before filing prior untimely foreign reporting forms, taxpayers should consider speaking with a Board-Certified Tax Law Specialist that specializes exclusively in these types of offshore disclosure matters.

Avoid False Offshore Disclosure Submissions (Willful vs Non-Willful)

In recent years, the IRS has increased the level of scrutiny for certain streamlined procedure submissions. When a person is non-willful, they have an excellent chance of making a successful submission to Streamlined Procedures. If they are willful, they would submit to the IRS Voluntary Disclosure Program instead. But, if a willful Taxpayer submits an intentionally false narrative under the Streamlined Procedures (and gets caught), they may become subject to significant fines and penalties.

**Need Help Finding an Experienced Offshore Tax Attorney?**

When it comes to hiring an experienced international tax attorney to represent you for unreported foreign and offshore account reporting, it can become overwhelming for taxpayers trying to trek through all the false information and nonsense they will find in their online research. There are only a handful of attorneys worldwide who are Board-Certified Tax Specialists and who specialize exclusively in offshore disclosure and international tax amnesty reporting.

Golding & Golding: About Our International Tax Law Firm

Golding & Golding specializes exclusively in international tax, specifically IRS offshore disclosure. Contact our firm today for assistance.