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 Taylor Nelson Amitrano LLP, 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.

Our Services

International Taxation Legal Expert

“I wholeheartedly give my highest recommendation for Lavar Taylor, Esquire, for both his legal acumen and his client relations’ skills. Mr. Taylor handled a complex, international tax matter for my family over the course of several years from start to finish. What impressed me the most about Mr. Taylor's legal work, was his ability to meticulously explain arcane tax law and its implications upon my family's case. My family and I would retain Lavar Taylor again without hesitation.”

Outstanding Results

“I hired Lisa Nelson and her firm to address a complex tax situation with the IRS in which the IRS was claiming I owed greater than $250,000. Lisa and her team quickly cut through the red-tape that is ever-present when interacting with the IRS. Lisa was successful in petitioning the IRS to review their agent’s action and the IRS quickly agreed with Lisa’s written appeal and that the IRS agent was indeed incorrect in their ruling, which saved me $250,000 in taxes.”

Wonderful Customer Service

“Lisa Nelson was amazing! She helped us and just gave us the assurance that everything will be OK. She kept in contact with us and told us she will keep us updated on everything that was going on with the IRS and she did! We were never disappointed! We are so happy with her work and I will recommend her to everyone!”

Results

“Lisa Nelson was professional and competent with our legal matters. Her responsiveness exceeded my expectations and the results of the case were very satisfactory. If I would describe Lisa in three words, it would be accountable, results-driven, and enthusiastic. Lisa clearly knew what she was responsible for and had the skills, knowledge, and sufficient influence to carry out her responsibilities. She maintained her focus on priorities and accurately predicted the anticipated consequences of our case. Lisa's deeply rooted enthusiasm for details gave me a sense of confidence that we had selected the right person to handle the job.”

Solved My Issues

“I have worked with a couple of tax attorneys with the same issue, all of them were chop shop style with no customization. Further, you could never get a hold of anyone. Jonathan Amitrano gets back to me with in a couple of hours at the most, and most importantly solved my issues while making me feel like things are being handled properly, which they were.”

Fantastic Case Resolution

“Lisa Nelson was able to help my client with a Casualty and Theft Loss disallowance who had been assessed $60,000 in taxes and penalties. My client was extremely happy and relieved that the tax lien was lifted and the balance was reduced to zero. Lisa was very personable, informative, and responded in a timely manner and we were very grateful for her assistance.”

Offshore Voluntary Disclosure Success

“I highly recommend Jonathan T. Amitrano and the Law Offices of A. Lavar Taylor. Jonathan assisted me and my family with a very complicated Offshore Voluntary Disclosure Program submission. Jonathan was an excellent advocate and was able to limit my civil tax exposure and eliminate my criminal tax exposure.”

Best Lawyer Ever

“Lisa Nelson is simply the best. I found her on Avvo to help me navigate through a complex IRS situation. My first contact with her was amazing, as she was so very nice and professional. The communication and support was exceptional and I could not have asked for anything better. She provided absolutely sound advice that later helped save me thousands of dollars. I’m so grateful for her representation, as she is hard worker, great communicator, and provided me updates late in the day and weekends. She is extremely intelligent and very knowledgeable. There is no other attorney would ever use then Lisa for future tax law advice.”

He Became A Real Friend To Me

“Jonathan Amitrano is one of the best lawyers I have met during my tax audit process and he became a real friend to me during the process. Jonathan communicates very effectively and is always reachable, and more importantly, he exceled in preparing and presenting my case to IRS auditor. This process resulted in a “win-win” for the whole audit process and the parties involved.”

Excellent Legal Counsel And Results

“Fortunately, I was put into contact with Lavar Taylor who after speaking with me stated that the IRS was wrong on every count in what they were accusing me of and that the actions by the IRS were unreasonable and egregious. In a series of letters and document submissions, Lavar convinced the IRS they had no case and the IRS attorney moved for dismissal of all charges. Lavar provided impeccable advice, guidance and defense. That he is eminently qualified goes without saying. He is both skillful and understanding, making his services all the more valuable. I am deeply indebted to him for his advice and counsel.”

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