Taxpayers with unreported foreign accounts or income often want to come forward, but doing it the wrong way can make things worse. M. Bradford Randolph, Esq., PLLC, helps New York clients navigate the offshore voluntary disclosure process, get compliant and address their potential exposure to penalties and other consequences. We handle the strategy and the paperwork so you are not facing the IRS alone.
Taking The Right Steps In The Offshore Voluntary Disclosure Program
In recent years, the U.S. government has begun investigating foreign banking institutions and prosecuting U.S. taxpayers who are not in compliance with our country's tax laws. Many people are not fully aware of U.S. reporting requirements on foreign income, as well as the reporting of business operations and financial accounts located in a foreign country. If you have foreign investments or property, inherited money in a foreign country or share a bank account with relatives living overseas, you may have an international tax compliance issue.
At the law office of M. Bradford Randolph, Esq., PLLC, we help individuals to use the IRS voluntary disclosure program to come into compliance with U.S. tax laws and minimize or possibly avoid many of the large penalties and criminal charges they would face if discovered.
The IRS voluntary disclosure program has recently changed but is still available to address tax noncompliance for both domestic and foreign income. Determining the best route to disclose tax noncompliance is crucial, and Attorney Randolph can help you to move forward with these issues. It can be important to move quickly on these matters considering that voluntary disclosure will likely no longer be available once the IRS becomes aware of your noncompliance.
Attorney Randolph has been practicing tax law for more than 25 years. In addition to being an attorney, Mr. Randolph is also a CPA. Mr. Randolph closely evaluates our clients' overseas accounts to determine if voluntary disclosure is advisable.
Located in Rockefeller Center in Manhattan, M. Bradford Randolph, Esq., PLLC, represents U.S. taxpayers located throughout the country and abroad.
Making a voluntary disclosure is a complex matter. Before deciding to participate, it is important to consult with an experienced tax lawyer who can advise you of your rights and counsel you on the best course of action to take.
Many people come to us afraid they have inadvertently underreported their foreign income. We thoroughly examine each client's finances to determine whether unreported income exists. Sometimes, the item is not income at all and does not require disclosure. When the item is income, we help clients to develop a disclosure plan.
Determining whether voluntary disclosure is advisable requires a careful evaluation of the taxpayer's circumstances, including overseas accounts, foreign investments, foreign income and other potential reporting obligations.
At the law office of M. Bradford Randolph, Esq., PLLC, Attorney Randolph assists clients in disclosing the information required to qualify for the voluntary disclosure program.
The process can involve reviewing overseas accounts and other financial information, determining whether unreported income exists, analyzing the applicable legal and tax issues and preparing the required documentation. Mr. Randolph can both analyze the applicable legal issues and also prepare the required amended tax returns.
The IRS voluntary disclosure program has changed over time, making it particularly important to determine the best route to disclose tax noncompliance. Attorney Randolph can help clients evaluate their circumstances and move forward with these issues.
Under the Foreign Account Tax Compliance Act (FATCA), the federal government now has the power to obtain financial information about U.S. taxpayers from foreign banks. Because many of these banks are located abroad in what were once considered "tax haven" countries, many U.S. taxpayers have lost their anonymity and are at risk of facing steep fines and possible criminal tax evasion and tax fraud charges if discovered.
The IRS has created a voluntary disclosure program that allows taxpayers to voluntarily disclose their overseas accounts and come into compliance with U.S. tax laws while escaping criminal charges.
The penalty rules are complex, and it is often difficult to determine which penalties are applicable and how they are calculated. Mr. Randolph is both an attorney and a CPA and will work with you to minimize any penalties.
At the law office of M. Bradford Randolph, Esq., PLLC, we provide reliable tax guidance and counsel. Many people come to us afraid they have inadvertently underreported their foreign income. We thoroughly examine each client's finances to determine whether unreported income exists.
Sometimes, the item is not income at all and does not require disclosure. When the item is income, we help clients to develop a disclosure plan.
It is important to understand that the U.S. government is continually improving its procedures to identify unreported foreign income. Attorney Randolph understands that tax evasion procedures are continuing to be developed — a workaround, in effect, to prevent existing IRS procedures from identifying foreign income and financial accounts.
Attorney Randolph cautions that these new tax evasion techniques provide a false sense of security. As a litigator, Attorney Randolph understands how quickly the IRS is learning about the new tax evasion techniques that are continually being developed.
The changing enforcement landscape makes it important to carefully evaluate foreign accounts, income and reporting obligations before deciding how to address potential noncompliance.
Foreign account and income issues can involve reporting requirements under the Foreign Account Tax Compliance Act (FATCA) and the Foreign Bank Account Report (FBAR).
FATCA gives the federal government the ability to obtain financial information about U.S. taxpayers from foreign banks, while FBAR and other foreign asset reporting requirements may apply to taxpayers with qualifying foreign financial accounts and assets.
For more information about foreign account reporting, FATCA compliance, penalties and IRS enforcement, see our FBAR & FATCA services.
If you have unreported foreign accounts, foreign income, foreign investments or other overseas financial interests, it is important to understand your rights and options before deciding how to proceed.
M. Bradford Randolph, Esq., PLLC, helps individuals address international tax compliance issues, evaluate voluntary disclosure options and take the necessary steps toward compliance.
Before deciding to participate in a voluntary disclosure program, consult with an experienced tax lawyer who can advise you of your rights and counsel you on the best course of action.
Arrange a consultation today by calling 212-759-0097 or contact the firm online.

For over 25 years, I’ve helped clients in New York and beyond with tax and business law matters. I’m committed to exceptional service and strong client relationships.

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