Tax Help for IRS Offshore Accounts, FBAR, Tax Filings, Tax Settlements = Attorney, Lawyer, Former IRS = THAILAND – Bangkok, Chiang Mai, Mueang Samut Prakan

Fresh Start Tax

 

We area Affordable full service tax firm that offers professional tax help for IRS offshore accounts, Fbar, tax compliance and tax settlements for taxpayers with filing compliance issues.

 

We have over 206 years of professional tax experience and over 60 years of working directly for the Internal Revenue Service in the local, district, and regional tax offices of the internal revenue service.

We were former IRS tax instructors and know the system well.

We are comprised of tax attorneys, tax lawyers, CPAs and former IRS agents who know their job inside and out.

Call us today for a free initial tax consultation and hear the truth about the IRS as a relates to offshore accounts and regulations thereof.

All calls  can be covered under attorney-client privilege if necessary.

 

The New Stream Line Procedures

The streamlined filing compliance procedures describe below are available to taxpayers certifying that their failure to report foreign financial assets and pay all tax due in respect of those assets did not result from willful conduct on their part.

The streamlined procedures are designed to provide to taxpayers in such situations with:

 

  •   a streamlined procedure for fling amended or delinquent returns, and
  •   terms for resolving their tax and penalty procedure for filing amended or delinquent returns, and
  •   terms for resolving their tax and penalty obligations.

 

As reflected below, the streamlined filing procedures that were first offered on September 1, 2012 have been expanded and modified to accommodate a broader group of U.S. taxpayers.

 

Major changes to the streamlined procedures include:

 

  • Extension of eligibility to U.S. taxpayers residing in the United States
  • Elimination of the $1,500 tax threshold, and
  •  Elimination of the risk assessment process associated with the streamlined filing compliance procedure announced in 2012.

 

Eligibility criteria for the streamlined procedures

 

The modified streamlined filing compliance procedures are designed only for individual taxpayers, including estates of individual taxpayers.

The streamlined procedures are available to both U.S. individual taxpayers residing outside the United States and U.S. individual taxpayers residing in the United States. Descriptions of the specific eligibility requirements for the streamlined procedures for both non-U.S. residents (the “Streamlined Foreign Offshore Procedures”) and U.S. residents (“Streamlined Domestic Offshore Procedures”) are set forth below.
Taxpayers must certify that conduct was not willful.

Taxpayers using either the Streamlined Foreign Offshore Procedures or the Streamlined Domestic Offshore Procedures, will be required to certify, in accordance with the specific instructions set forth below, that the failure to report all income, pay all tax and submit all required information returns, including FBARs (FinCEN Form 114, previously Form TD F 90-22,1) was due to non-willful conduct.

IRS has initiated a civil examination of taxpayer’s returns for any taxable year.

If the IRS has initiated a civil examination of taxpayer’s returns for any taxable year, regardless of whether the examination relates to undisclosed foreign financial assets, the taxpayer will not be eligible to use the streamlined procedures.

Taxpayers under examination may consult with their agent.

A taxpayer under criminal investigation by IRS Criminal Investigation is also ineligible to use the streamlined procedures.

Taxpayers eligible to use streamlined procedures who have previously filed delinquent or amended returns must pay previous penalty assessments.

Taxpayers eligible to use the streamlined procedures who have previously filed delinquent or amended returns in a attempt to address U.S. tax and information reporting obligations with respect to foreign financial assets (so-called “quiet disclosures” made outside of the Offshore Voluntary Disclosure Program (OVDP) or its predecessor programs) may still use the streamlined procedures by following the instructions set forth below.

However, any penalty assessments previously made with respect to those filing will not be abated.

Taxpayers who want to participate in the streamlined procedures need a valid Taxpayer Identification Number.

All returns submitted under the streamlined procedures must have a valid Taxpayer Identification Number.

For U.S. citizens, resident aliens, and certain other individuals, the proper TIN is a valid Social Security Number (SSN).

For individuals who are not eligible for an SSN or ITIN will not be processed under the streamlined procedures.

However, for taxpayers who are ineligible for an SSN but do not have an ITIN, a submission my be made under the streamlined procedures if accompanied by a complete ITIN application.

 

OVDP or streamlined procedures

Taxpayers who are concerned that their failure to report income, pay tax, and submit required information returns was due to willful conduct and who therefore seek assurance that they will not be subject to criminal liability and/or substantial monetary penalties should consider participating the Offshore Voluntary Disclosure Program and should consult with their professional or legal advisers.

 

General treatment under the streamlined procedures

 

Tax returns submitted under either the Streamlined Foreign Offshore Procedures or the Streamlined Domestic Offshore Procedures will be processed like any other return submitted to the IRS.

Receipt of the returns will not be acknowledged by the IRS and the streamlined filing process will not culminate in the signing of a closing agreement with the IRS.

Returns submitted under either the Streamlined Foreign Offshore Procedures or the Streamlined Domestic Offshore Procedures will not be subject to IRS audit automatically, but they may be selected for audit under the existing audit selection processes applicable to any U. S. tax return and may also be subject to verification procedures in that the accuracy and completeness of submissions may be checked against information received from banks, financial advisors, and other sources.

Returns submitted under the streamlined procedures may be subject to IRS examination, additional civil penalties, and even criminal liability, if appropriate.

Taxpayers who are concerned that their failure to report income, pay tax, and submit required information returns was due to willful conduct and who therefore seek assurances that they will not be subject to criminal liability and/or substantial monetary penalties should consider participating in the Offshore Voluntary Disclosure Program and should consult with their tax professional or legal advisers.

After a taxpayer has completed the streamlined filing compliance procedures, he or shewill be expected to comply with U.S. law for all future years and file returns according to regular filing procedures.

 

Coordination between streamlined procedures and OVDP

Once a taxpayer makes a submission under either the Streamlined Foreign Offshore Procedures or the Streamlined Domestic Offshore Procedures, the taxpayer may not participate in OVDP. Similarly, a taxpayer who submits to an OVDP voluntary disclosure letter pursuant to OVDP FAQ 24 on or after July 1, 2014, is not eligible to participate in the streamlined procedures.

A taxpayer eligible for treatment under the streamlined procedures who submits, or who has submitted, a voluntary disclosure letter under the OVDP (or any predecessor offshore voluntary disclosure program) prior to July 1, 2014, but who does not yet have a fully executed OVDP closing agreement, may request treatment under the applicable penalty terms available under the streamlined procedures.

 

Please NOTE:

A taxpayer seeking such treatment does not need to opt out of the OVDP but will be required to certify, in accordance with the instructions set forth below, that the failure to report all income, pay all tax, and submit all information returns, including FBARs, was due to non-willful conduct.

As part of the OVDP process, the IRS will consider this request in light of all the facts and circumstances of the taxpayer’s case and will determine whether or not to incorporate the streamlined penalty terms in the OVDP closing agreement.

 

Tax Help for IRS Offshore Accounts, FBAR, Tax Filings, Tax Settlements = Attorney, Lawyer, Former IRS =  THAILAND – BANGKOK, CHIANG MAI

US Tax Lawyer, Attorney = Offshore Banking, International Tax Law, FATCA, FBAR Representation = THAILAND – BANGKOK, CHIANG MAI, MUEANG SAMUT PRAKAN

Fresh Start Tax

 

We are a full service professional tax firm that specialize in offshore banking, international tax law, FBAR, FATCA & tax representation.

 

We have been serving taxpayers since 1982 and our A+ rated by the Better Business Bureau.

On staff are tax attorneys, tax lawyers, certified public accountants, and former IRS agents, managers and taxes structures.

Because of our years of experience at the Internal Revenue Service we know the system and the tax law as it pertains to offshore banking and international tax the requirements thereof.

You may contact us or Skype us today for a free initial tax consultation.

The conversation can b covered under attorney-client privilege if requested.

We have successfully represented thousands of clients since 1982

 

Changes to Offshore Programs; Revisions Ease Burden and Help More Taxpayers Come into Compliance

 

The Internal Revenue Service has made major changes in its offshore voluntary compliance programs, providing new options to help both taxpayers residing overseas and those residing in the United States.

The changes are anticipated to provide thousands of people a new avenue to come into compliance with their U.S. tax obligations.

The tax changes include an expansion of the streamlined filing compliance procedures announced in 2012 and important modifications to the 2012 Offshore Voluntary Disclosure Program (OVDP).

The expanded streamlined procedures are intended for U.S. taxpayers whose failure to disclose their offshore assets was non-willful.

Balanced against the modified programs is the government’s ongoing effort to combat the misuse of offshore assets.

You should know that the IRS, working closely with the U.S. Department of Justice, continues to investigate foreign financial institutions that may have assisted U.S. taxpayers in avoiding their tax filing and payment obligations.

In addition, on July 1, the new information reporting regime resulting from the Foreign Account Tax Compliance Act (FATCA) will go into effect.

Thousands of foreign financial institutions will begin to report to the IRS the foreign accounts held by U.S. persons.They mean business!

The current Offshore Voluntary Disclosure Program was launched in 2012 and is the successor to prior voluntary programs offered in 2011 and 2009.

Since the launch of the first program, more than 45,000 taxpayers have come into compliance voluntarily, paying about $6.5 billion in taxes, interest and penalties.

The expansion of the streamlined procedures and modifications to OVDP reflect the thoughtful input of the tax community given the growing awareness among U.S. taxpayers of their offshore tax obligations.

Streamlined Procedures Expanded

The changes announced today make key expansions in the streamlined procedures to accommodate a wider group of U.S. taxpayers who have unreported foreign financial accounts.

The original streamlined procedures announced in 2012 were available only to non-resident, non-filers. Taxpayer submissions were subject to different degrees of review based on the amount of the tax due and the taxpayer’s response to a “risk” questionnaire.

The expanded streamlined procedures are available to a wider population of U.S. taxpayers living outside the country and, for the first time, to certain U.S. taxpayers residing in the United States.

 

The changes include:

 

Eliminating a requirement that the taxpayer have $1,500 or less of unpaid tax per year;
Eliminating the required risk questionnaire;

Requiring the taxpayer to certify that previous failures to comply were due to non-willful conduct.

For eligible U.S. taxpayers residing outside the United States, all penalties will be waived.

For eligible U.S. taxpayers residing in the United States, the only penalty will be a miscellaneous offshore penalty equal to 5 percent of the foreign financial assets that gave rise to the tax compliance issue.

Offshore Voluntary Disclosure Program (OVDP) Modified

 

The changes  also make important modifications to the OVDP.

The changes include:

Requiring additional information from taxpayers applying to the program;

 

  • Eliminating the existing reduced penalty percentage for certain non-willful taxpayers in light of the expansion of the streamlined procedures;

 

  • Requiring taxpayers to submit all account statements and pay the offshore penalty at the time of the OVDP application;

 

  • Enabling taxpayers to submit voluminous records electronically rather than on paper;

 

  • Increasing the offshore penalty percentage (from 27.5% to 50%) if, before the taxpayer’s OVDP pre-clearance request is submitted, it becomes public that a financial institution where the taxpayer holds an account or another party facilitating the taxpayer’s offshore arrangement is under investigation by the IRS or Department of Justice.

 

FBAR Tax FBAR Services

 

US Tax Lawyer, Attorney = Offshore Banking, International Tax Law, FATCA, FBAR Representation = THAILAND – BANGKOK, CHIANG MAI