Offshore Tax Lawyer – IRS Tax Experts – Former IRS, File, Settle, Negotiations, Representation, Tax Problems

by Fresh Start Tax | Jul 9, 2012 | Back Taxes, FBAR, Offshore Program, Offshore Tax Problems, Representation, Tax Lawyer

We are a Tax Specialty Firm. We are IRS Tax Experts in Offshore Tax Issues, Compliance and Tax Problems.

Call us for a no cost tax consult, 1-866-700-1040.

We are comprised of Tax Lawyers, Board Certified Tax Attorneys, CPA’s and Former IRS Agents.

We can handle all IRS filings, file back or lost tax returns, settle and negotiate Tax Debt and fully handle all IRS Tax Representation or Tax Problems.

You will never speak to the IRS.

Offshore Tax is one of the many specialties at Fresh Start Tax LLC, a Global Company.

We have over 60 years of direct IRS work related experience in the local, district and regional tax offices.

We taught Tax Law at the IRS.

Terms of Compliance of Offshore Tax Compliance.

What are the terms of the 2011 Offshore Voluntary Disclosure Initiative?

Under the new terms of the 2011 Offshore Voluntary Disclosure Initiative, taxpayers absolutely must:

1. Taxpayers are to provide copies of previously filed original (and, if applicable, previously filed amended) federal income tax returns for tax years covered by the voluntary disclosure;

2. Taxpayers are to provide complete and accurate amended federal income tax returns (for individuals, Form 1040X, or original Form 1040 if delinquent) for all tax years covered by the voluntary disclosure, with applicable schedules detailing the amount and type of previously unreported income from the account or entity e.g., Schedule B for interest and dividends, Schedule D for capital gains and losses, Schedule E for income from partnerships, S corporations, estates or trusts.

3. Taxpayer are to file complete and accurate original or amended offshore-related information returns (see FAQ 29 for certain dissolved entities) and Form TD F 90-22.1 Report of Foreign Bank and Financial Accounts, commonly known as an “FBAR” for calendar years 2003 through 2010;

4 Taxpayers are to cooperate in the voluntary disclosure process, including providing information on offshore financial accounts, institutions and facilitators, and signing agreements to extend the period of time for assessing tax and penalties;

Offshore Penalty Provisions:

1. Pay 20% accuracy-related penalties under IRC § 6662(a) on the full amount of your underpayments of tax for all years;

2.Pay failure to file penalties under IRC § 6651(a)(1), if applicable;

3.Pay failure to pay penalties under IRC § 6651(a)(2), if applicable;

4.  In lieu of all other penalties that may apply, including FBAR and offshore-related information return penalties, a miscellaneous Title 26 offshore penalty, equal to 25% (or in limited cases 12.5% (see FAQ 53) or 5% (see FAQ 52)) of the highest aggregate balance in foreign bank accounts/entities or value of foreign assets during the period covered by the voluntary disclosure,

5.Submit full payment of all tax, interest, accuracy-related penalty, and, if applicable, the failure to file and failure to pay penalties with the required submissions set forth in FAQ 25 or make good faith arrangements with the IRS to pay in full, the tax, interest, and these penalties (see FAQ 20 for more information regarding a taxpayer’s ability to fully pay) (the suspension of interest provisions of IRC § 6404(g) do not apply to interest due in this initiative); and

Taxpayers must also execute a Closing Agreement on Final Determination Covering Specific Matters, Form 906.

Offshore Tax Lawyer – IRS Tax Experts – Former IRS, File, Settle, Negotiations, Representation