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Offshore & Domestic Voluntary Disclosure

The Voluntary Disclosure program is a way for taxpayers with an out of court settlement for an undisclosed amount to contact the IRS and correct their taxes. A Voluntary Disclosure only occurs when information is complete, honest, and timely. This practice is the longest standing program offered by the IRS and does not apply to illegal matters. 

At the Law Offices of A. Lavar Taylor, we are the ally you need when voluntarily disclosing your assets to the IRS. Our lawyers can significantly reduce penalties owed and offer shielding from serious criminal chargers.

Our attorneys have significant experience in advising and assisting clients who are out of compliance with the income tax laws, due to the failure to report income from foreign sources, and due to the failure to file information returns relating to foreign assets and income. We represent individuals, shareholders, partners, members, corporations, LLC’s, partnerships, estates, foreign account holders, beneficiaries of foreign trusts and others, who must deal with the potential consequences of a failure to stay in compliance, with the laws relating to foreign assets and income. These are matters are known as Voluntary Disclosure, Foreign Bank Act Report (FBAR) and Offshore Foreign Tax Compliance and our legal expertise includes:

  • Advising clients on how to bring their status back into compliance
  • Representing targets and witnesses in criminal investigations that involve a failure to comply with laws relating to foreign income and assets
  • Representing targets and witnesses in criminal prosecutions that involve a failure to comply with laws relating to foreign income and assets
  • Advising clients whether to take advantage of the Voluntary Disclosure programs of the IRS and other tax authorities (both offshore and domestic), including the new Streamlined Program offered by the IRS
  • Representing clients who wish to make a Voluntary Disclosure
  • Representing clients who did not make a voluntary disclosure and whose income tax returns are now being audited
  • Representing clients in FBAR audits
  • Representing clients administratively and in court to challenge penalties proposed or assessed for failure to file information returns relating to foreign income and/or assets, including FinCen Form 114 (FBARs), IRS Forms 926, 3520, 3520A, 5471, 5472, 8865 and 8938

Our clients tell us often how difficult it is for them to file a multitude of confusing, mandatory forms completely on their own. If you are a shareholder or officer of a foreign corporation, a beneficiary or grantor of a foreign trust, a partner in a foreign partnership, or if you have bank accounts or other assets located outside the United States, you may be required to file information returns with the IRS. Failure to timely file these information returns can result in the imposition of very large penalties.

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