by Fresh Start Tax | Sep 29, 2012 | Expatriate Tax, FBAR, Representation, Tax Lawyer
We are comprised of Tax Attorneys, CPA’s and Former IRS Agents who are FBAR Experts.
We have a world wide tax practice offering help to any person(s) having issues, questions or problems with the Filing and Reporting of FBAR.
The Offshore Voluntary Disclosure Program allows taxpayers to come forward and pony up for any monies not reported to the IRS.
The taxpayer is required to pay all tax plus penalties and interest and in turn many times the IRS will forgo criminal prosecution which is the main leverage that the IRS holds over the heads of taxpayers. Prison time is the hammer that drives this program. So much so that the IRS posts a list on the irs.gov website of all FBAR prosecutions.
The IRS is very serious of about this FBAR reporting and filing due to the sheer volume of funds it brings in to the US stream of revenue.
The IRS collected just north of $5 billion as a result of the first three years of filing and reporting due to the blow up of UBS.
As a result, IRS is beefing up their tax treaties and for both banks and financial institution. As a result these financial institutions are starting to share their information with the IRS and the US government. In many cases this sharing is due to the fact that they fear government reprisal from the US.
FBAR is here to stay.
It is best to get an opinion of a Tax Attorney or Tax Lawyer if you need to file and report. Different options exists on how to report and become come compliant with US tax law to avoid both criminal problems and civil problems. In many cases Fresh Start Tax LLC can minimize penalties and interest.
Most of the FBAR filers and reporters have very little to worry about. If you live in the Philippines or the surrounding areas call us today to find out more. 1-866-700-1040.
One of the common question we are asked.
What are some of the criminal charges I might face if I don’t come in under voluntary disclosure and the IRS examines me?
Possible criminal charges related to tax returns include tax evasion (26 U.S.C. § 7201), filing a false return (26 U.S.C. § 7206(1)) and failure to file an income tax return (26 U.S.C. § 7203). Willfully failing to file an FBAR and willfully filing a false FBAR are both violations that are subject to criminal penalties under 31 U.S.C. § 5322.
A person convicted of tax evasion is subject to a prison term of up to five years and a fine of up to $250,000.
Filing a false return subjects a person to a prison term of up to three years and a fine of up to $250,000.
A person who fails to file a tax return is subject to a prison term of up to one year and a fine of up to $100,000.
Failing to file an FBAR subjects a person to a prison term of up to ten years and criminal penalties of up to $500,000.
The OVDP
U.S. Taxpayer assets can be repatriated legally through a new program commonly known as the 2012 OVDP (offshore voluntary disclosure program), the penalty framework requires individuals to pay a penalty of 27.5 percent of the highest aggregate balance in foreign bank accounts,entities or value of foreign assets during the eight full tax years prior to the disclosure.
That is up from 25 percent in the 2011 program.
Some taxpayers will be eligible for 5 or 12.5 percent penalties; these remain the same in the new program as in 2011.
Still others may be better off “opting out” of the program because their violations are not willful.
Check with us today to hear the truth about FBAR and stop the worry.
FBAR File & Report, Philippines, US Tax Lawyers, Attorneys, Former IRS, FBAR Help, Affordable, World Wide Experts
by Fresh Start Tax | Sep 28, 2012 | Expatriate Tax, FBAR, Offshore Program, Tax Lawyer, Tax Returns
First it was UBS. No one knew where it would go from there.
But now Lichtenstein went down and caved in to US pressure and the US has turned its attention to other countries including Hong Kong.
The US government is putting on political pressure on foreign governments to hand over names and bank account holders to ensure that those individuals have filed FBAR’s and paid there legal tax.
If you have not done so and need professional tax representation call us today.
We are comprised of Tax Attorneys, Tax Lawyers, CPA’s and Former IRS agents.
One of the reasons you want to use our firm is because of our expertise with the IRS. We have over 206 years of professional tax expereince and over 60 years of working directly for the IRS in the local, district and regional offices of the IRS.
We taught Tax Law at the IRS and know all the policies. and settlement policies.
We can file your FBAR, file your amended returns and settle your case. Stop the worry today.
It is very important that individuals or businesses that may have issues or problems to speak to tax professionals and discuss these issues before the IRS gets involved. and they will get involved.
Make sure you are absolutely clear on this, the IRS is coming.
The success so far by the US government and the IRS.
After the first two Programs run by the US government the IRS collected just north of $5 Billion in back taxes and penalties.With those types of numbers it does not take a genius that the Feds have found a source of revenue. Since both parties always pledges not to raise taxes this is an easy fix. Just enforce the tax laws to individuals who are wealthy and have fudge on there tax returns. There leverage, prison time.
The IRS is ramping up enforcement and the Feds are backing them up.
Next year the Administration is funding the IRS another $500,000 million to pursue tax cheats and work on non- compliance.
Make no mistake about it, the IRS is coming.
What happened in Liechtenstein.
Few saw this coming. With Liechtenstein being a small Alpine village of 36,000 people many thought it would never fall to IRS pressure, but it did.
Liechtenstein finally informed on their Bank Clients on the U.S. Tax Evasion Request to report on certain foreign accounts.
Liechtenstein has told there American clients of the principality’s oldest bank that U.S. authorities have requested their account data as they widen a tax probe for potential tax evasion and potential tax fraud. Investors are scrambling.
Accounts at’ Liechtensteinische Landesbank AG (LLB)” that contained at least $500,000 at any time since the beginning of 2004 are covered by the information request, according to a May 30 letter sent to a client by the principality’s tax authority. We have no idea how many accounts are included on this request however the word on the streets, “thousands”.
What is FATCA?
The Foreign Account Tax Compliance Act (FATCA) improves tax compliance involving foreign financial assets and offshore accounts. Under FATCA, certain U.S. taxpayers with specified foreign financial assets must report those assets to the IRS on Form 8938.
Call us today to find out more.
FATCA will require foreign financial institutions to report directly to the IRS information about financial accounts held by U.S. taxpayers.
The IRS offers an offshore voluntary disclosure program to help people get current with their taxes. The current program is open for an indefinite period until otherwise announced.
1-866-700-1040 Free tax consult Skype available
File FBAR – Hong Kong – Report & Settle Without Fear – US Tax Attorney Lawyers, Former IRS – Expatriate Help
by Fresh Start Tax | Sep 27, 2012 | Expatriate Tax, FBAR, Tax Lawyer
We are FBAR & Expatriate Tax Experts. We are comprised of Tax Attorneys, Tax Lawyers, Former IRS Agents who have over 205 years of professional tax experience and over 60 years of working directly for the IRS.
We can file FBAR reports, amended tax returns and work out a tax settlement.
Free tax consults. 1-866-700-1040.
Stop the worry today. We are a different tax firm from most because we taught tax law at the IRS and know the system and tax policies.
Important news for those living in Greece, Cyprus and the surrounding areas.
The latest news that came out of Lichtenstein regarding FBAR was not a good sign for taxpayers who need to file FBAR and amended tax returns.
Earlier this year Liechtenstein finally informed on their Bank Clients on the U.S. Tax Evasion Request. Lichtenstein was a haven for taxpayers to hide there monies out of the long arm of the IRS and the US government. Uncle Sam won and is pressing on to bigger targets.
The US Government Request of Records.
Request of records were made by the US government of the Bank accounts at’ Liechtensteinische Landesbank AG (LLB)” that contained at least $500,000 at any time since the beginning of 2004 are covered by the information request, according to a May 30 letter sent to a client by the principality’s tax authority.
The US also announced that in the Liechtenstein group request, U.S. authorities are also targeting lawyers, accountants, financial advisers, asset managers and those responsible for professional “asset protection,” who “conspired with a U.S. taxpayer to commit U.S. crimes or provided assistance,” according to the letter.
IRS is continuing to amass more information and pursue more people internationally, the risk to individuals hiding assets offshore is increasing.
Our advice, file before IRS finds you! We can limit your exposure today.
Some of the areas that IRS announced initiatives were in Greece, Cyprus, Dubai , Hong Kong and Japan. The long arm of the IRS will be making its way soon.
The IRS collected over $5 Billion big ones as a result of the first two FBAR initiatives and the IRS already knows were to hunt. The fear of criminal prosecution looms large.
IRS wants to give those hiding money in foreign accounts a tough, fair way to resolve their tax problems once and for all. And it gives people a chance to come in before IRS find you.
The goal of the Internal Revenue Service is to get people back into the U.S. tax system. Criminal investigators and Revenue Agents are teaming up to combat international tax evasion. New Government Divisions are being set up to make this a top priority for the IRS.
IRS also has additional cases and banks under review. The situation will just get worse in the months ahead for those hiding assets and income offshore.
IRS is even so bold as to post all FBAR victories including prison sentences on their website.
We have successfully handled a number of FBAR cases and we can take the fear and worry away. Call us today. 1-866-700-1040.
FBAR, Greece, Cyprus, Unfiled, Late FBAR , Tax Attorney Lawyers, Former IRS , Representation, Civil & Criminal , Expatriate Help
by Fresh Start Tax | Sep 27, 2012 | Expatriate Tax, FBAR, IRS Tax Problem, Tax Lawyer
Unfiled, Delinquent FBAR – Liechtenstein: A Sign of What’s to Come
Stop the worry today! We have handled many successful FBAR clients, including those with an unfiled or delinquent FBAR.
Call us today and we can explain to you how to get back in the system. do not let Unfiled or Delinquent FBARs stress you out. We can settle your case without worry.
There has been a natural fear built in the FBAR program and we can help relieve you of the fear and worry. We can file all back FBAR reports, file your amended 1040’s and work out a successful tax settlement.
Most of the time we will recommend “quiet settlements.”
We have over 205 years of professional tax experience and over 60 years of direct experience at the IRS in the local, district and regional offices of the Internal Revenue Service.
We taught Tax Law at the IRS and know all the tax polices and tax procedure to settle your case. 1-866-700-1040.
Liechtenstein
With the explosion of the UBS the domino’s started to fall and one of the questions everyone was asking was, ” would Liechtenstein fall ?”.
It did and now, taxpayers are scrambling.
Liechtenstein finally informed on their Bank Clients on the U.S. Tax Evasion Request
Liechtenstein has told American clients of the principality’s oldest bank that U.S. authorities have requested their account data as they widen a tax evasion and potential tax fraud probe.
Accounts at‘ Liechtensteinische Landesbank AG (LLB)” that contained at least $500,000 at any time since the beginning of 2004 are covered by the information request, according to a May 30 letter sent to a client by the principality’s tax authority.
Liechtenstein facilitated the so-called group request from the U.S. by amending a tax law in March.
Liechtenstein’s second-biggest bank, also known as LLB, is one of 11 financial firms, including Credit Suisse Group AG (CSGN) and Julius Baer Group Ltd. (BAER), being investigated as part of a U.S. probe of offshore tax evasion.
The Stakes
The stakes for Swiss banks were raised after the Department of Justice indicted Wegelin & Co. on Feb. 2 for allegedly helping customers hide money from the Internal Revenue Service. The IRS is taking a very aggressive approach to collect monies on FBAR and are funding huge amounts of revenue to go after the deep foreign taxpayers pockets of monies.
The Motivation.
“The motivation for the law is the Landesbank issue, which has accelerated the process,” said Mario Frick, a partner at Liechtenstein law firm Seeger, Frick & Partner. “For a certain period of time, it will be possible to make group requests to clean up the past and the issue of legacy assets.”
Landesbank, which had 48.1 billion Swiss francs ($50 billion) of assets under management at the end of 2011, confirmed it has received a group request via the Liechtenstein authorities, Cyrill Sele, a spokesman for the bank in Vaduz, said in an e-mailed response to questions.
Third Parties
“The ruling to extend the period of applicability back to the tax year 2001 in the administrative assistance law with the U.S. is limited to 12 months from the date it comes into force,” said Sele. It “is closely linked to the ongoing U.S. offshore voluntary disclosure program.”
Those affected by the U.S. request for information have the right to appeal, according to the letter.
In the Liechtenstein group request, U.S. authorities are also targeting lawyers, accountants, financial advisers, asset managers and those responsible for professional “asset protection,” who “conspired with a U.S. taxpayer to commit U.S. crimes or provided assistance,” according to the letter.
The sign of what is to come
“It’s a sign that the U.S. is not just focused on Switzerland, but on all offshore jurisdictions with Singapore, Dubai and Hong Kong very much on the radar screen,” said Milan Patel, a partner at Zurich-based law firm Anaford AG. “This request appears to be much more expansive than the agreement with Switzerland and aims to get information on third parties.”
UBS Precedent
Swiss banks are seeking a settlement with the U.S. as Liechtenstein’s larger Alpine neighbor, the world’s biggest center for offshore wealth, tries to shed its image as a haven for undeclared assets. That may involve negotiating separate deferred prosecution agreements with U.S. authorities.
UBS AG, the biggest Swiss bank, avoided prosecution in 2009 by paying $780 million, admitting it fostered tax evasion and giving the IRS data on more than 250 accounts. It later turned over data on another 4,450 accounts. Before the UBS deferred- prosecution deal, U.S. prosecutors said the bank managed $20 billion in undeclared assets for American clients.
Landesbank declined to comment on whether the handover of account data under the group request would allow the bank to enter a deferred prosecution agreement.
Christof Buri, a spokesman for larger Liechtenstein rival LGT Group, which had 86.9 billion francs of assets under management at the end of last year, said the bank only has tax- compliant U.S. clients. The bank, owned by Liechtenstein’s princely family, declined to comment further.
Unwinding Secrecy
Liechtenstein started to unwind secrecy after data stolen from LGT was used by Germany to prosecute tax evaders in 2008. Former Deutsche Post AG (DPW) Chief Executive Officer Klaus Zumwinkel was convicted of tax evasion and received a two-year suspended prison sentence plus a penalty of 1 million euros ($1.25 million).
Under pressure from the U.S., Germany and France, Liechtenstein said in March 2009 that it would conform with tax standards set out by the Organization for Economic Cooperation and Development to avoid being blacklisted as a tax haven.
Markus Amman, a spokesman for the Liechtenstein government, and Katja Gey, who helped negotiate a tax deal for the principality with the U.K., didn’t answer calls to their mobile phones.
“It’s only a question of time, say three to five years, when this type of group request will become standard for future business,” said lawyer Frick. “Liechtenstein is a small country that has had a reputation for not cooperating in the field of tax and that’s something that has to change. We have to find new areas of business.
”Contribution made by Bloomberg/ Dylan Griffiths in Geneva. thank you.
The Bottom Line. Unfiled, Delinquent FBAR
Taxpayers with worries should contact our office today for a no cost consult. We can inform you of the possibility of making a quiet disclosure. 1-866-700-1040.
Speak to a Expert FBAR Tax Attorney, Tax Lawyer, CPA or Former IRS Agents.
Unfiled, Delinquent FBAR – Liechtenstein: A Sign of What’s to Come
by Fresh Start Tax | Jul 25, 2012 | Christian IRS Tax Relief, Expatriate Tax, FBAR, Tax Lawyer, Tax Settlements
We are a Christian Tax Firm <>< specializing in IRS FBAR and Expatriate Tax Representation.
Call us today for a free Christian tax consult 1-866-700-1040.
We taught Tax Law at the IRS. We know the tax policies and tax procedures because we taught them at the IRS.
We are Biblical Based Christian Tax Firm in all our dealings so expect to hear the truth about your case.
We support Grace FM and Reach FM, Christian Radio.
We are comprised of Board Certified Tax Attorneys, CPA’s and Former IRS Agents, Managers and Instructors.
We have over 206 years of professional tax experience and over 60 years with the Internal Revenue Service.
How do you discern godly counsel?
Psalm 37:30 The godly offer good counsel, they know what is right from wrong.
Proverbs 18:2 Fools have no interest in understanding; they only want to offer their own opinions.
FBAR and Expatriates
With the Federal Government finding over $5.5 billion dollars in Offshore Programs in the last two years, the Fed came out and said it will spend over $500,000 million in new revenue to help catch tax cheats and tax crimes.
What is the FBAR Voluntary Disclosure Practice
It is currently the practice of the IRS that a voluntary disclosure will be considered along with all other factors in the investigation in determining whether criminal prosecution will be recommended.
This voluntary disclosure practice creates no substantive or procedural rights for taxpayers, but rather is a matter of internal IRS practice, provided solely for guidance to IRS personnel. It is best to contact us directly because each case is based on its own merits.
A voluntary disclosure ( VD ) will not automatically guarantee immunity from prosecution; however, a voluntary disclosure may result in prosecution not being recommended. This practice does not apply to taxpayers with illegal source income.This is where we come in. The general rule, contact IRS before they contact you.
A voluntary disclosure occurs when the communication is truthful, timely, complete, and when:
1. the taxpayer shows a willingness to cooperate and does in fact cooperate with the IRS agent in determining his or her correct tax liability,
2. when the taxpayer makes a good faith arrangements with the IRS to pay in full, the tax, interest, and any penalties determined by the IRS to be applicable. Remember it is possible to abate penalties and interest. Honesty goes along way!
3. A full disclosure is timely if it is received before:
a. the IRS has initiated a civil examination or criminal investigation of the taxpayer, or has notified the taxpayer that it intends to commence such an examination or investigation;
b. the IRS has received information from a third party (e.g., informant, other governmental agency, or the media) alerting the IRS to the specific taxpayer’s noncompliance;
c. the IRS has initiated a civil examination or criminal investigation which is directly related to the specific liability of the taxpayer; or
d. the IRS has acquired information directly related to the specific liability of the taxpayer from a criminal enforcement action.
4. Any taxpayer who contacts the IRS in person or through a representative regarding voluntary disclosure will be directed to Criminal Investigation for evaluation of the disclosure.
Call today for a no cost Christian Tax Consult 1-866-700-1040.
FBAR, Christian IRS Tax Problem Help, FBAR, Expatriate, Attorneys, Former IRS, FBAR, Expat – Experts
FBAR, Christian, IRS Tax Help, FBAR, Expatriate, Attorneys, Former IRS, FBAR, Expat Experts
by Fresh Start Tax | Jul 17, 2012 | Back Taxes, Expatriate Tax, IRS Tax Audit, Tax Help, Tax Lawyer
Expatriate Tax Audits 1-866-700-1040
We are a professional tax firm specializing in Expatriate Tax Representation.
Call us for a free tax consultation. 1-866-700-1040. Speak DIRECTLY to a tax professional.
Let us take the worry and fear out of IRS. Let our years of experience be your best friend. We know how to fight back and win.
We are a specialty tax firm comprised of Board Certified Tax Attorneys, CPA’s and Former IRS agents and managers.
We have over 60 years with the IRS in the local, district and regional offices. We have over 205 years of professional tax experience.
If you are expecting a IRS tax audit or you will owe back taxes, call us for a no cost professional tax consultation. Should you owe back taxes to the IRS we will review the possibility of a IRS tax debt settlement called an offer in compromise.
We taught Tax Law at the IRS
How the IRS Selects Tax Returns for Examination
The IRS selects returns using a variety of methods, including:
1.Potential participants in abusive tax avoidance transactions.
Some returns are selected based on information obtained by the IRS through efforts to identify promoters and participants of abusive tax avoidance transactions. Examples include information received from “John Doe” summonses issued to credit card companies and businesses and participant lists from promoters ordered by the courts to be turned over to the IRS.
2.Computer Scoring. The IRS computer system has kicked out your tax return.
Some returns are selected for examination on the basis of computer scoring. Computer programs give each return numeric “scores”. The Discriminant Function System (DIF) score rates the potential for change, based on past IRS experience with similar returns.
The Unreported Income DIF score rates the return for the potential of unreported income. IRS personnel screen the highest-scoring returns, selecting some for audit and identifying the items on these returns that are most likely to need review.
3. Large Corporations( over 5 millions dollars.)
The IRS examines many large corporate returns annually.
4.Information Matching.
IRS examines over 1.4 million taxpayers through this form of audit.
Some returns are examined because payer reports, such as Forms W-2 from employers or Form 1099 interest statements from banks, do not match the income reported on the tax return.
5. Related Examinations.( because they found errors on related tax returns to yours)
Returns may be selected for audit when they involve issues or transactions with other taxpayers, such as business partners or investors, whose returns were selected for examination.
6. Specialized Programs
Area offices may identify returns for examination in connection with local compliance projects. These projects require higher level management approval and deal with areas such as local compliance initiatives, return preparers or specific market segments.
Expatriate Tax Audits, Owe Back Taxes, Settlements, Offer in Compromise – IRS Tax Experts
Call us today for a no cost professional tax consult. 1-866-700-1040.
