by Fresh Start Tax | Jul 5, 2012 | FBAR, IRS Tax Debt, Tax Lawyer
Expatriate Professional Tax Services. We are comprised of Tax Attorneys, CPAs, Former IRS Agents with over 205 years of total professional tax experience and over 60 years of direct work experience at the IRS in the local, district and regional tax office.
We taught Tax Law at the IRS. We are true professional tax experts.
Our firm handles all of tax compliance with our unparalleled tax knowledge of international tax regulations and understanding of the needs of United States citizens living abroad. We offer a full range of professional tax service for all your accounting and IRS needs including tax planning.
Call us today for a no cost professional tax consult. 1-866-700-1040.
Tax Tip regarding Form 8854 – the importance of the filing of this form
What to do if you have not filed a Form 8854?
individual taxpayer(s) that renounced their United States citizenship or terminated their long-term resident status for tax purposes on or before June 3, 2004 must file a Form 8854 to comply with the notification requirements under IRC 877 and 877A.
Furthermore, pursuant to IRC 7701(n), until such individuals both files a Form 8854 with the IRS and notifies either the Department of State or of Homeland Security of their expatriation or termination of long-term resident status for tax purposes, such individuals will continue to be treated as if they were still United States citizens or residents for tax purposes.
With the new modernization program under the new health care program and the hiring of new agents, we can expect to see a huge crack down in this area.
Also, for individuals that expatriated after June 3, 2004, IRC 6039G requires annual information reporting for each taxable year during which such an individual is subject to the rules of IRC 877.
The annual Form 8854 is due on the date that the individual’s U.S. income tax return for the taxable year is due or would be due if such a return were required to be filed.
Ex-Pat – Professional Tax Services – Attorneys, Tax Lawyer , CPAs, Former IRS – Expat Tax Experts- Call for a no cost professional tax consult. 1-866-700-1040.
We also specialize in the filing of back tax returns and tax settlements.
by Fresh Start Tax | Jul 4, 2012 | Back Taxes, FBAR, IRS Tax Problem, Representation, Tax Lawyer, Tax Returns
FBAR Filings – Free Tax Advice – Tax Attorneys, Lawyers – Former IRS
There are many questions regarding the filing of FBAR and making Voluntary Disclosures to the IRS.
There are also various opinions on how this should be done.
It is always best to speak directly to a tax attorney, tax lawyer or Former IRS Agent to go over all your tax options regarding FBAR and Voluntary Disclosure.
We are a professional tax firm specializing in FBAR and ExPat cases.
These are two of the most common questions asked:
1. 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 these 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.
The IRS along with different countries are putting in tax treaties to deal with the problem of unreported FBAR based on bank account information they are currently receiving.
Due to recent funding the IRS is ramping up CADE 2, the new IRS computer system that will help full compliance.
It is in the best interest to all taxpayers to find the IRS before they find you.
2. 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.
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 not recommend criminal prosecution to the Department of Justice.
The general rule of thumb, file first and beat criminal prosecution.
FBAR & Voluntary Disclosure – IRS FBAR Tax Relief – Tax Experts – Tax Attorneys, CPA’s, Former IRS
Our Company Resume: ( Since 1982 )
- Our staff has collectively over 205 years of Professional IRS Tax Representation Experience
- On staff, Board Certified Tax Attorney’s, IRS Tax Lawyers, Certified Public Accountants, Enrolled Agents,
- We taught Tax Law in the IRS Regional Training Center
- Former IRS Agents, Managers and Instructors with over 60 years experience in the local, district and regional IRS offices.
- Highest Rating by the Better Business Bureau “A”
- Fast, affordable, and economical
- Licensed and certified to practice in all 50 States
- Nationally Recognized Veteran /Published Former IRS Agent
- Nationally Recognized Published EZINE Tax Expert
- As heard on GRACE 90.3 FM Monthly Radio Show-Business Weekly
by Fresh Start Tax | Jul 4, 2012 | Back Taxes, Expatriate Tax, FBAR, IRS Tax Advice, Tax Lawyer, Tax Returns
At Last, a tax reprieve on foreign income reporting and filing your back tax returns, well maybe.
American that live abroad will get a reprieve from the IRS this year on reporting on foreign assets.
The IRS said it will allow some United States citizens, including dual citizens, who have not filed income tax returns or not disclosed their foreign bank accounts, to come forward without facing onerous penalties or the threat of prosecution.
This is what the IRS calls a tax amnesty of sorts.
The Internal Revenue Service said the reprieve, to begin Sept. 1, would also apply to U.S. expatriates with foreign retirement plans, including Canadian ones.
But read the fine print on this one! ( Only low risk compliance taxpayers are invited to this party )
The optional procedure just announced is available only to Americans who owe little or no back taxes, not to those who have squirreled away substantial amounts in secret offshore accounts that they have knowingly failed to disclose to the IRS.
This announcement is for small type of taxpayers.
If you are not sure what categorize you fall in you may want to call us for a no cost professional tax consultation. 1-866-700-1040.
The IRS statement said the new guidelines were for “low compliance risk” taxpayers, generally people who have simple returns and owe $1,500 or less in tax for any covered years. Yes, this is for the low end of taxpayers.
IRS is about to pound this area of non-compliance due to the very fact that the Offshore Program over the past years has brought in a kings ransom to the IRS, a whooping $4 Billion Large. IRS will not stop.
It also follows complaints by tax lawyers that many U.S. expatriates have been unaware of the new rules on tax returns and disclosure of foreign bank accounts.
IRS feels that many of these taxpayers were not willful tax evaders, but simply uninformed about filing returns and, if needed, disclosures known as Foreign Bank and Financial Account Reports, or FBARs.
Many taxpayers were just plain ignorant of the tax laws and the IRS does not intend to hurt this type of taxpayer.
The IRS said that under the new procedures, taxpayers would have to file delinquent tax returns for the past three years and delinquent FBARs for the past six years.
The IRS said “higher compliance risk” taxpayers would be subject to a more thorough review and, potentially, an audit or a referral to CI or Criminal Division Review.
The IRS also said taxpayers would be barred from the disclosure program if they challenged in foreign courts the disclosure of their accounts while failing to inform the U.S. Justice Department of such challenges.
You can expect the IRS to being a full court press from now on, they plan for bleed this Offshore Program for as much as it can.
As a result of the Obama-Care Program the IRS will be given $500 million for budgetary purposes.
You better attorney up if need be. If you are in full compliance no need to worry.
Call us for a free tax consult for tax advice.
We are staffed with Tax Attorneys, Tax Lawyers, CPA’s and Former IRS agents. 1-866-700-1040
by Fresh Start Tax | Jul 3, 2012 | FBAR, Representation, Tax Lawyer
Foreign Bank Account Reports – FBAR Lawyers, Former IRS – Free Tax Advice – FBAR Experts
FBAR is here to stay.IRS has found a pot of gold at the end of this FBAR rainbow.
The IRS and the U.S. Department of Treasury will make a living from FBAR alone. FBAR, Foreign Bank Account Reporting is paying the bills of the Treasury.
The Feds have collected over $4 Billion big ones so far and that they say is just the tip of the iceberg. Much more is coming, the more tax treaties the more money. When Lichtenstein falls it all goes.
The IRS is hiring more agents and gearing up their computer system CADE 2 to find tax cheats and tax evaders through their new computerized systems and it is working.
For years IRS has been getting by with 80’s technology and now with the new funding will catch up to modernization of modern day businesses and banks.
FBAR ( Foreign Bank Account Reports ) will not go away until the IRS sucks all the blood out of all the taxpayers who have the responsibility to file and report thru FBAR.
The Report of FinCEN, the definitive source for FBAR
Foreign Bank and Financial Accounts Report (FBAR) Responsibilities
“The Financial Crimes Enforcement Network (FinCEN) issued a rule that amends the Bank Secrecy Act (BSA) implementing regulations regarding the Report of Foreign Bank and Financial Accounts (FBAR).
The FBAR filing requirements, authorized under one of the original provisions of the BSA, have been in place since 1972.
The FBAR form is used to report a financial interest in, or signature or other authority over, one or more financial accounts in foreign countries. No report is required if the aggregate value of the accounts does not exceed $10,000.
On February 26, 2010, FinCEN issued a Notice of Proposed Rule making (NPRM) addressing the FBAR rules.
The final rule adopts the proposed changes with slight modifications.
The preamble to the new final rule explains FinCEN’s approach to issues raised in comments submitted in response to the NPRM from tax professionals and industry experts.
The preamble to the final rule: and I quote
explains whether an account is foreign and therefore reportable as a foreign financial account and addresses the treatment of custodial accounts in this context;
revises the definition of signature or other authority to more clearly apply to individuals who have the authority to control the disposition of assets in the account by direct communication (whether in writing or otherwise) to the foreign financial institution;
explains that an officer or employee who files an FBAR because of signature or other authority over the foreign financial account of their employer is not expected to personally maintain the records of the foreign financial accounts of their employer;
and also,
advises filers that they may rely on provisions of this final rule in order to determine their filing obligation for FBARs in those cases where filing was properly deferred under prior Treasury guidance.”
What the taxpayer should do re: (Foreign Bank Account Reports – FBAR)
Each taxpayer is responsible for their own reporting and financial disclosures to the IRS. At the present time IRS is giving grace to certain individuals where tax fraud is not involved. There will be a period of time in the near future in which the IRS will no longer forgive non-filers and delinquents.
Call us today for a no cost professional tax consultation. 1-866-700-1040
Speak directly to FBAR Tax Lawyers, Attorneys, and Former IRS Agents.
Foreign Bank Account Reports – FBAR Lawyers, Former IRS – Free Tax Advice – FBAR Experts
Areas of Professional Tax Practice:
- Same Day IRS Tax Representation
- FBAR Tax Representation
- Offers in Compromise or IRS Tax Debt Settlements
- Immediate Release of IRS Bank Levies or IRS Wage Garnishments
- Tax Relief from a IRS Bill, Letter or Notice of “Intent to Levy”
- IRS Tax Audits
- IRS Hardships Cases or Unable to Pay
- Payment Plans, Installment Agreements, Structured agreements
- Abatement of Penalties and Interest
- State Sales Tax Cases
- Payroll / Trust Fund Penalty Cases / 6672
- Filing Late, Back, Unfiled Tax Returns
- Tax Return Reconstruction if Tax Records are lost or destroyed
Our Company Resume: ( Since 1982 )
- Our staff has collectively over 205 years of Professional IRS Tax Representation Experience
- On staff, Board Certified Tax Attorney’s, IRS Tax Lawyers, Certified Public Accountants, Enrolled Agents,
- We taught Tax Law in the IRS Regional Training Center
- Former IRS Agents, Managers and Instructors with over 60 years experience in the local, district and regional IRS offices.
- Highest Rating by the Better Business Bureau “A”
- Fast, affordable, and economical
- Licensed and certified to practice in all 50 States
- Nationally Recognized Veteran /Published Former IRS Agent
- Nationally Recognized Published EZINE Tax Expert
- As heard on GRACE 90.3 FM Monthly Radio Show-Business Weekly
by Fresh Start Tax | Jul 3, 2012 | Expatriate Tax, FBAR, Representation, Tax Lawyer, Tax News, Tax Returns
We are Ex- Pat and FBAR tax specialists. We are tax experts. As Former IRS agents we taught Tax Law at the IRS.
We have successful handled a great deal of both Ex- Pat and FBAR cases.
You can call today for a no cost professional confidential consultation.
We are comprised of Board Certified Tax Attorneys, Lawyers, CPA’s and Former IRS Agents.
We have over 205 years of professional tax experience and over 60 years of direct work experience with the IRS. We worked in the local, district and regional offices of the Internal Revenue Service.
Do you need to file a tax return for the IRS?
Under the new health care plan IRS is coming. The current tax appropriations under the new law is about to let the IRS loose.
Among the various new requirements of the IRS that are contained in IRC 877 and 877A, individuals that renounced their U.S. citizenship or terminated their long-term resident status for tax purposes after June 3, 2004 are required to certify to the IRS that they have satisfied all federal tax requirements for the 5 years prior to expatriation.
If all your federal tax requirements have not been satisfied for the 5 years prior to expatriation, even if the individual does not meet the monetary thresholds in IRC 877 or 877A, the individual taxpayer will be subject to the IRC 877 and 877A expatriation tax provisions.
Individual(s) that have expatriated should file all tax returns that are due, regardless of whether or not full payment can be made with the return.
Depending on an individual’s circumstances, a taxpayer filing late may qualify for a payment plan.
All payment plans to the IRS require continued compliance with all filing and payment responsibilities after the plan is approved and throughout the course of the plan.
IRS imposes a $10,000 penalty may be imposed for failure to file Form 8854 when required.
IRS is sending notices to expatriates that have not complied with the Form 8854 requirements, including the imposition of the $10,000 penalty where appropriate.
IRS is acquiring lists through tax treaties with and through various countries.
Failure to file or not including all the information required by the form or including incorrect information will result in large penalties.
FBAR REQUIREMENTS
If you have a financial interest in or signature authority over a foreign financial account, including a bank account, brokerage account, mutual fund, trust, or other type of foreign financial account, the Bank Secrecy Act may require you to report the account yearly to the Internal Revenue Service by filing Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR).
The FBAR is required because foreign financial institutions may not be subject to the same reporting requirements as domestic financial institutions. You should call us if you have questions.
Federal Tax Investigators with the IRS use FBARs to help identify or trace funds used for illicit purposes or to identify unreported income maintained or generated abroad.
It is important to know that the IRS is receiving $500 million dollars in funding under the new health care plan, yes, the new health care plan.
A lot of that budget will be at the expense of Ex-Pats and FBAR
We are EXPAT, FBAR Tax Specialists. Comprised of Tax Attorneys, Lawyers and Former IRS. We are affordable, experienced and will tell you the truth about your case.
by Fresh Start Tax | Jul 3, 2012 | FBAR, Tax Lawyer
Needless to say the reason you have looked us up is because the Internal Revenue Service is spending a lot and time and money to get FBAR under control. This is something you may be worried about or just have questions.
As former IRS Agent I can tell you from work experience, the IRS was sealed out of Foreign Bank accounts until the UBS debacle. Since UBS the IRS is on steroids going after taxpayers who are hiding money offshore. If this is you, tax representation is a must.
It is important to know that each case is uniquely different. Some of the factors the IRS reviews are:
1. Size of the case,
2. The history of the taxpayer,
3. Money involved,
4. Chance of a successful audit, collection or prosecution,
5. Badges of Fraud.
As a Former IRS Agent we looked at all these factors before spending loads of time on each case. It was just not prudent to after everyone.
With that said, your case is unique and needs to be looked at in the eyes of the IRS and it is important to understand their determining criteria.
At Fresh Start Tax L.L.C. we are a professional tax firm comprised of Board Certified Tax Attorneys, Lawyers, CPA’s and Former IRS Agents and Instructors.
When employed at the IRS I taught Tax Law.
If you have questions about FBAR and tax representation call us for a no cost professional consult. 1-866-700-1040
All your information is confidential and you will be afforded attorney – client privileged.
We have over 205 years of professional tax experience and over 60 years of direct work experience at the IRS.
Our Tax Attorneys and Tax Lawyers can help and work through this situation.
Call today and speak directly to a Lawyer/Attorney. 1-866-700-1040
FBAR – Lawyers/Attorneys – Former IRS, Tax Experts – Affordable
