by Fresh Start Tax | Jul 25, 2012 | FBAR, Tax Lawyer
We are Tax Experts in FBAR. We can take the fear and worry out of FBAR.
Call today and speak directly to Tax Attorneys, Former IRS Agents and hear the truth about FBAR Amnesty . 1-866-700-1040.
We have over 206 years of total IRS tax experience and over 60 years of direct IRS tax work experience in the local, district and regional offices of the IRS.
IRS has different amnesty programs and will announce them at different times when the top brass believe it is in the best interest of the government.
It is best to check with us on your individual situation to find out the different tax options open to you depending on the current climate of the IRS.
The last thing you want to experience is a criminal investigation from the IRS. Besides prison time, the fines and penalties will drain the very life out of you.
Should you have any questions, call us today for a no cost professional consult and hear the truth about FBAR Amnesty and your case.
Things you should know about FBAR.
1.Who must file an FBAR?
Any United States person who has a financial interest in or signature authority or other authority over any financial account in a foreign country, if the aggregate value of these accounts exceeds $10,000 at any time during the calendar year.
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2. What constitutes signature or other authority over an account?
A person has signature authority over an account if such person can control the disposition of money or other property in it by delivery of a document containing his or her signature (or his or her signature and that of one or more other persons) to the bank or other person with whom the account is maintained.
3. Who has authority over a Bank Account
Other authority exists in a person who can exercise power that is comparable to signature authority over an account by direct communication to the bank or other person with whom the account is maintained, either orally or by some other means.
What are some of the criminal charges I might face if I don’t come in under voluntary disclosure and the IRS finds me?
4. What are Criminal Charges that can be invoked by the IRS?
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).
The failure to file an FBAR and the filing of a false FBAR are both violations that are subject to criminal penalties under 31 U.S.C. § 5322.
Tax Evasion.
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.
False Tax Return.
Filing a false return subjects a person to a prison term of up to three years and a fine of up to $250,000.
Failure to File.
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.
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by Fresh Start Tax | Jul 24, 2012 | Abatements, FBAR, IRS Penalties, Tax Lawyer, Tax Settlements
FBAR Penalties – Remove, Settle – FBAR Tax – Former IRS, Attorneys – FBAR Tax Experts – FBAR Consultants
We are a IRS tax specialty firm. We tax experts in IRS matters including FBAR.
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We have a combined 205 years of professional tax experience and over 60 years of direct IRS tax experience in the local, district and regional offices of the Internal Revenue Service.
We have been practicing Tax Law since 1982 and we are “A” rated by the BBB.
On staff are Former IRS Appeals Agents and Tax Attorneys who are tax experts in matters of Penalty abatement and removal.
We have been settling cases with the IRS since 1982. We know all the tax policies and tax procedures because we taught Tax Law at the IRS.
Call us for a no cost consult and hear your options, 1-866-700-1040.
FBAR Penalties, procedures and applications.
The IRS has been delegated authority to assess FBAR civil penalties. There are civil penalties for negligence, pattern of negligence, non-willful, and willful violations. Each case is different and the results vary from cases to case.
IRS penalties are be asserted only to promote compliance with the FBAR reporting and record keeping requirements.
In exercising IRS discretion, tax examiners consider whether the issuance of a warning letter and the securing of delinquent FBARs, rather than the assertion of a penalty, will achieve the desired result of improving compliance in the future. We hope!
FBAR civil penalties have varying upper limits, but no floor.
The IRS audit examiner discretion is necessary because the total amount of penalties that can be applied under the statute can greatly exceed an amount that would be appropriate in view of the violation. You must hope the tax examiner is fair and uses good judgement.
IRS tax examiners are expected to exercise discretion, taking into account the facts and circumstances of each case, in determining whether penalties should be asserted and the total amount of penalties to be asserted.
Because FBAR penalties do not have a set amount, IRS has developed penalty mitigation guidelines to assist examiners in the exercise of their discretion in applying these penalties.
The FBAR mitigation guidelines are only intended as an aid for the examiner in determining an appropriate penalty amount.
The IRS tax examiner must still consider whether a warning letter or a penalty amount that is less than what would be called for under the mitigation guidelines would be more appropriate given the facts and circumstances of a particular case.
FBAR penalties are determined per account, not per unfiled FBAR, for each person required to file.
IRS penalties apply for each year of each violation.
As noted above, however, examiners are expected to exercise discretion, taking into account the facts and circumstances of each case, in determining whether penalties should be asserted and the total amount of penalties to be asserted.
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by Fresh Start Tax | Jul 24, 2012 | FBAR, Tax Lawyer
We are a a professional tax firm that specializes in all IRS tax matters and FBAR case matters.
You may contact us for a free consultation and speak directly to a Tax Lawyer that is an expert in FBAR. 1-866-700-1040.
We are fair, honest and will tell you the truth about your FBAR matter. We can take away the worry and fear from any anxiety you may be feeling. You will never have to speak to the Internal Revenue Service. Our Tax Lawyers are excellent.
Do not feel threatened by the IRS, let our years of IRS tax experience work for you.
We have over 206 years of professional tax experience and over 60 years of working directly for the IRS in the local, regional and district offices including teaching tax law at the IRS.
Voluntary Disclosure for FBAR
Two of the most asked questions are found below. Should you have any questions please call us regarding these questions or others you may have.
Why should I make a voluntary disclosure?
Taxpayers with undisclosed foreign accounts or entities should make a voluntary disclosure because it enables them to become compliant, avoid substantial civil penalties and generally eliminate the risk of criminal prosecution.
Making a voluntary disclosure also provides the opportunity to calculate, with a reasonable degree of certainty, the total cost of resolving all offshore tax issues.
Taxpayers who do not submit a voluntary disclosure run the risk of detection by the IRS and the imposition of substantial penalties, including the fraud penalty and foreign information return penalties, and an increased risk of criminal prosecution.
What is the IRS’s Voluntary Disclosure Practice?
The Voluntary Disclosure Practice is a longstanding practice of IRS Criminal Investigation of taking timely, accurate, and complete voluntary disclosures into account in deciding whether to recommend to the Department of Justice that a taxpayer be criminally prosecuted. IRS is just beginning to ramp up future enforcement and has a budget of $500 Million additional set for this year alone.
It enables non-compliant taxpayers to resolve their tax liabilities and minimize their chances of criminal prosecution.
When a taxpayer truthfully, timely, and completely complies with all provisions of the voluntary disclosure practice, the IRS will usually not recommend criminal prosecution to the Department of Justice.
Call us to walk you thru this process. 1-866-700-1040.
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by Fresh Start Tax | Jul 23, 2012 | FBAR, IRS Tax Problem, Tax Help, Tax Lawyer
FBAR – Help, Problems, Resolutions – Tax Attorneys, Former IRS – FBAR Experts 1-866-700-1040
Call today for a no cost professional tax consultation 1-866-700-1040 and speak directly to a FBAR tax attorney would is a tax expert.
If you are looking for FBAR Help or have a tax problem relating to FBAR call us today for a no cost professional tax consultation to permanently get your FBAR problem resolved.
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Free consult 1-866-700-1040. Speak directly to Tax Attorneys, Lawyers or Former IRS agents.
We have over 206 years pf professional tax experience and over 60 years of working directly for the IRS.
We taught Tax Law at the IRS. It only makes sense directly to Former IRS agents who know the internal workings of IRS. Use our experience for your benefit.
Who must file an FBAR?
Any United States person who has a financial interest in or signature authority or other authority over any financial account in a foreign country, if the aggregate value of these accounts exceeds $10,000 at any time during the calendar year. See also Notice 2010-23.
Make sure you contact IRS before the IRS contacts you!
Overview for FBAR
The Financial Crimes Enforcement Network (FinCEN) delegated to IRS its enforcement authority for penalties imposed under Title 31, Sections 5314 – 5321 for the failure to file Form TD F 90-22.1 Report Of Foreign Bank And Financial Accounts (FBAR) .
Form TD F 90-22.1 , Report of Foreign Bank and Financial Accounts, must be filed by US persons who have a financial interest in, signature authority, or other authority over one or more financial accounts in foreign countries with an aggregate value exceeding $10,000 at any time during the calendar year.
If you failure to file this form it could result in civil and or criminal penalties. The civil penalties may be appealed. Should the case go criminal it will be a long hard road.
FBAR penalties may come to Appeals as stand-alone cases or together with a related income tax or international penalty.
Call us for a free tax consultation today and see how we can give you professional FBAR help to completely solve your tax problems.
We have been resolving FBAR cases since 1982 and we are the go to firm for professional Fbar help.
FBAR, Help, Problems, Resolutions, Tax Attorneys, Former IRS, FBAR, Experts
by Fresh Start Tax | Jul 23, 2012 | FBAR, Tax Lawyer
We are FBAR Tax Experts. Attorneys, Lawyers and Former IRS Agents who know the system and techniques of FBAR cases.
We are comprised of Board Certified Tax Attorneys, Tax Lawyers, CPAs, and former IRS agents, managers and instructors. We taught IRS Tax Law.
We have a combined 205 years of professional tax experience and over 60 years with the IRS.
We handle all FBAR resolutions and FBAR tax settlements.
The specific reason you would use our firm is simply this, we taught Tax Law at the IRS and know their settlement techniques and tax policies to settle and manage cases.
Few professional tax firms have any direct IRS expertise or experience.
What is going on with FBAR.
There is absolutely no question that the Federal Government will be in full engagement for FBAR tax cases. With the IRS collecting over $5.2 Billion in their overseas operations on last count, this three year program has yielded tremendous benefits from very wealthy taxpayers. The IRS has found a huge revenue source without raising taxes.
Coupled with the fear of criminal prosecution, makes FBAR a win-win for the IRS.
Under the new budget guidelines for the upcoming year the IRS was awarded $500 Million to sure up there compliance programs and the FBAR Program is a high priority target for the IRS.
What is the FBAR Filing Criteria
In order to determine whether or not the FBAR is required, all of the following must apply:
1. The filer is a U.S. person;
2. The U.S. person has a financial account(s);
3. The financial account is in a foreign country;
4. The U.S. person has a financial interest in the account or signature or other authority over the foreign financial account; and,
5. The aggregate amount(s) in the account(s) valued in dollars exceed $10,000 at any time during the calendar year.
If you need any questions answered call us for a no cost professional tax consult. 1-866-700-1040.
You can request attorney client privilege if necessary.
Get of hold of IRS before they get a hold of you.
FBAR Tax Attorneys, Tax Lawyers, FBAR Resolution, Settlements, Former IRS, FBAR Problem Experts
by Fresh Start Tax | Jul 23, 2012 | FBAR, Tax Lawyer
We have a National Tax Practice specializing in FBAR matters world wide. We are comprised of Board Certified Tax Attorneys, Lawyers, CPA’s and Former IRS Agents and Managers.
We have over 205 years of professional tax experience and over 60 years of working directly for the IRS in the local, district and regional offices of the IRS. We also worked in IRS Management.
As a result of our years of direct IRS experience we know all the tax policies, tax procedures, and settlement techniques because of expertise in IRS.
We also taught Tax Law at the IRS. We taught New IRS Agents their craft.
With a National Tax Practice we are licensed to practice anywhere in the world in regard to IRS Tax Matters.
We are directly involved in tax settlements, the filing of back tax returns, negotiations of penalties and interest, offers in compromise and lastly IRS tax audits.
You will never have to speak to the IRS. It is very important for taxpayers to understand it is much better for us or the taxpayer to notify IRS before they notify you the taxpayer.
In cases where the taxpayer made full disclosures few cases were ever brought to CI.
Call us for a no cost consultation. 1-866-700-1040
FBAR also known as Foreign Bank and Financial Accounts:
What is an FBAR? – An FBAR is a Report of Foreign Bank and Financial Accounts. The form number is TD F 90-22.1 (PDF).
Who must file an FBAR? – Any United States person who has a financial interest in or signature authority or other authority over any financial account in a foreign country, if the aggregate value of these accounts exceeds $10,000 at any time during the calendar year.
Call or SKYPE us for a no consult and speak directly to a tax professional.
All conversations can be made if request under attorney client privilege.
