by Fresh Start Tax | Jun 28, 2012 | Abatements, FBAR, IRS Tax Problem, Tax Lawyer, Tax Returns, Tax Settlements, Uncategorized
With the aggressive position of the IRS on FBAR cases and the the new federal funding given to the IRS, the Service is going to ramp up a full force major attack on all FBAR cases.
The IRS has been training new Revenue Agents to have become ROBO-FBAR AGENTS to scare the taxpayers into submission and full tax compliance.
It has worked so far.
The commissioner of the IRS announced the IRS has collected over $5 Billion and much more is expected to come. Fear is a great motivator.
With this said, if currently you have professional tax needs in this area call us today for a free tax consult.
Speak directly with Board Certified Tax Attorneys, Tax Lawyers, CPAs and Former IRS Agents who are tax experts in the field of FBAR tax settlements, tax negotiations. We can answer all your questions with a no cost first consult.
What is new with FBAR
The standard penalty was recently increased from 25 percent to 27.5 percent.
In December 2011 the IRS issued FS-2011 that appeared to soften their attitude and provided that penalties will not be imposed in all cases. Check with us and see if you qualify for this.
Taxpayer (s) that remain out of compliance will likely eventually show up on the IRS radar screen. With IRS cutting more deals with countries and with new tax treaties being developed with new countries every day, FBAR will become a daily topic within the IRS because of the sheer volume of revenue it brings in.
New Revenue Agents Groups within the IRS have been formed with many Agents currently being trained simply to work these FBAR cases.
It should also be known these are highly skilled agents working these case.
If a taxpayer is notified the IRS is seeking FBAR info, it is vitally important they seek out legal representation.
Many times the IRS will play the criminal card.
On large dollar cases, Agents have the ability to make a criminal referrals to CI if the Agent feels that tax fraud is involved.
The IRS post lists on their website of all their current convictions.
Innocent Taxpayers with Compliance Problems
Many of our clients/taxpayers come from places all over the world.
Most do not face exposure to criminal tax issues.
Criminal tax problems typically involve intentional actions to hide the ownership of assets and income such as offshore trusts, pure and out right fraud and shell- type companies.
Most, about 95 % of our clients have simply failed to file FBARs, some have not filed tax returns for many years and these taxpayers do not owe any U.S. tax due to foreign tax credits as they pay higher rate foreign tax. Most are simply unaware or uninformed.
Reasonable cause and relief from penalties
There are a array of reasons the the IRS abates penalties and interest. There is a long list found on our website.
We usually go over the fact patterns of each individual case and develop a tax strategy for a successful abatement of penalties and interest.
On staff is a Former IRS Appeals Agent who over his 35 year career at IRS has probably worked more Abatement case than any I know.He exclusively works our abatement cases.
We handle all FBAR Cases, Tax Settlements, Negotiations. We can file all unfiled tax returns.
We are compromised of Tax Attorneys, Tax Lawyers, CPA’s and Former IRS Agents
We are true FBAR Tax Experts, call us today. 1-866-7001-040
Thank you.
by Fresh Start Tax | Jun 28, 2012 | FBAR, IRS Tax Debt, Representation, Tax Lawyer, Tax Returns, Tax Settlements
FBAR – Tax Lawyers – File and Settle – IRS Tax & FBAR Experts
Take the fear out of FBAR.
We are a professional tax firm specializing in FBAR tax filings and tax negotiations. We are compromised of Board Certified Tax Lawyers, Tax Attorneys, CPA’s and Former IRS Agents who where both teaching instructors and former IRS managers when employed by the IRS. We have a combined 60 years who experience at the IRS.
We also taught Tax Law while employed by the IRS.
Our firm specializes in the filing, negotiation and tax debt settlements of World Wide FBAR cases.
The IRS viewpoint on FBAR
The Internal Revenue Service is starting ramp up enforcement of there International Tax Program and the latest goldmine for the feds is found in the FBAR filings and payment.
To date the IRS has found over $5 billion Dollars in collectables. With that type of money on the table the IRS is not going to quit. This makes the IRS look good!
As a matter of fact the IRS is dedicating much of there millions in enforcement budget specifically to this FBAR project.
After speaking to several IRS agents, the management of the IRS is going to “make FBAR headlines with there enforcement”. They want to scare taxpayers to death.
What hangs over the head of many of the taxpayers is the fear of going to jail and this is huge. It makes people jump and scares them into tax compliance. And, it has worked!
Who Must File an FBAR
United States persons are required to file an FBAR if:
The United States person had a financial interest in or signature authority over at least one financial account located outside of the United States; and
The aggregate value of all foreign financial accounts exceeded $10,000 at any time during the calendar year to be reported.
United States person means United States citizens; United States residents; entities, including but not limited to, corporations, partnerships, or limited liability companies created or organized in the United States or under the laws of the United States; and trusts or estates formed under the laws of the United States.
Exceptions to the Reporting Requirement
Exceptions to the FBAR reporting requirements can be found in the FBAR instructions.
There are filing exceptions for the following United States persons or foreign financial accounts:
1.Certain foreign financial accounts jointly owned by spouses;
2.United States persons included in a consolidated FBAR;
3.Correspondent/nostro accounts;
4.Foreign financial accounts owned by a governmental entity;
5. Foreign financial accounts owned by an international financial institution;
6.IRA owners and beneficiaries;
7.Participants in and beneficiaries of tax-qualified retirement plans;
8.Certain individuals with signature authority over but no financial interest in a foreign financial account;
9.Trust beneficiaries; and
10.Foreign financial accounts maintained on a United States military banking facility.
If you are looking to have true FBAR experts handle your case call us today for a no cost consult. 1-866-700-1040.
You will speak directly to a Tax Lawyer, Tax Attorney, CPA or a Former IRS Agents.
by Fresh Start Tax | Jun 27, 2012 | Abatements, Back Taxes, Expatriate Tax, FBAR, Income Tax Preparation, IRS Tax Problem, Representation, Tax Lawyer, Tax Returns, Tax Settlements
The IRS is already starting to bear down very hard on Ex-Pats and there late, past due and or delinquent tax returns.
The IRS has dedicated so much more revenue to oversees tax collections and tax audits. These groups of agents are called Revenue Agents. They are currently being trained to go after easy tax money and easy tax targets, and those are the Expats. they have been well trained and also experienced for fraud indications.
The IRS has finally wised up and realized that instead of going after the deadbeats who lives within the boundaries or confines of this great country, the new found jackpot is where the money and the leverage is sitting and that my friends is the IRS new target, Ex Pats and FBAR.
Many of the Ex-Pats who have not filed were unaware of the filing issue or the tax laws. I would say over 50% of the cases we work are due to the lack of knowledge and ignorance of the law. If that is the case, we can get penalties and interest, removed or abated for reasonable cause.
How we handle Ex Pat cases regarding late, past due, back or delinquent returns:
We send to IRS a Power of Attorney indicating that the IRS is not to talk or contact the taxpayer.
We then secure the necessary documentation from our client and secure internal records that the IRS has in house. IRS stores all income information for 7 years.
In the case of lost records we file reconstructed tax returns. We have filed so many reconstructed tax returns these never become a problem. A good deal of taxpayers who have lost there records are afraid to file because many years have gone by. Believe it or not IRS is happy to get the returns and get you back in tax compliance.
Keep one thing in mind, if the IRS sends you a letter about filing your late, back, past due or delinquent tax returns and you do not respond,the IRS has the right to file for you and this a called a substitute for return. ( SRF )
The bottom line, we can file all your tax returns with or without records and also settle your back IRS tax debt.
We are comprised of Tax Attorneys, CPA’s and Former IRS agents with over 60 years of professional tax experience.
Call us today for a no cost consult. 1-866-700-1040
Call us and see how easy this can be. You can do this worry free!
by Fresh Start Tax | Jun 27, 2012 | FBAR, IRS Tax Problem, Representation, Tax Lawyer
Make sure you find IRS before they IRS finds you. As a former IRS Agent take my advice to heart. The FBAR beast is coming.
IRS cannot wait to get to the next round of FBAR cases cranked up. Billions of you’re dollars are waiting for them.
Why?
The IRS in the past few years has just collected over $5 Billion big ones from the FBAR Program.
The IRS has just dedicated millions of more dollars to fund enforcement and the training of new IRS agents to be part of the new IRS mean lean collecting machine.
IRS Statement by commissioner Doug Shulman
“We continue to make strong progress in our international compliance efforts that help ensure honest taxpayers are not footing the bill for those hiding assets offshore,” said IRS Commissioner Doug Shulman. “People are finding it tougher and tougher to keep their assets hidden in offshore accounts.”
Shulman said the IRS offshore voluntary disclosure programs have so far resulted in the collection of more than $5 billion in back taxes, interest and penalties from 33,000 voluntary disclosures made under the first two programs. In addition, another 1,500 disclosures have been made under the new program announced in January.
This by far is the most successful program ever launched the the IRS. FBAR is a huge hit and the IRS billing machine does not plan to stop.
IRS is securing new treaties with new countries so with each treaty opens up the books and records of banks allowing the IRS to go after tax cheats.
Professional Tax Representation
If you are looking for an experienced tax firm to represent your best interest, lower your tax debt including penalties and interest call us today for a free professional tax consult and speak directly to Tax Attorneys or CPAs.
Attorney- Client Privilege.
Call us at 1-866-700-1040. We are affordable and assessable.
by Fresh Start Tax | Jun 27, 2012 | FBAR, IRS Tax Problem, Representation, Tax Help, Tax Lawyer, Tax News
If you need IRS tax help to solve a IRS tax problem cause by the new FBAR requirements call Fresh Start Tax L.L.C. today for tax representation and never speak to the IRS.
Call us today for a free tax consult – 1-866-700-1040
We have a World Wide Tax Practice with years of tax experience.
We are affordable and accessible.
We are staffed with Tax Attorneys, CPA’s and Former IRS agents. We have over 205 years of professional tax experience and over 60 years of working directly for the IRS.
We taught Tax Law at the IRS.
The Offshore Program FBAR
The new program launched by the Federal Government is raising hoards of revenue for the Federal Government.
The IRS has announced that efforts Tops $5 Billion.
New Details:
There are new details on the Voluntary Disclosure Program and Closing of Offshore Loophole
The new details regarding the voluntary disclosure program announced in January, including tightening the eligibility requirements.
The IRS is pressing very hard on the FBAR issue because of the large dollars on the table.
It is the most productive program in the history of the IRS.
IRS Statement:
“We continue to make strong progress in our international compliance efforts that help ensure honest taxpayers are not footing the bill for those hiding assets offshore,” said IRS Commissioner Doug Shulman. “People are finding it tougher and tougher to keep their assets hidden in offshore accounts.”
Shulman said the IRS offshore voluntary disclosure programs have so far resulted in the collection of more than $5 billion in back taxes, interest and penalties from 33,000 voluntary disclosures made under the first two programs. In addition, another 1,500 disclosures have been made under the new program announced in January.
Voluntary Disclosure Program
The voluntary disclosure programs are part of a wider effort by the IRS to stop offshore tax evasion and ensure tax compliance. This includes beefed up enforcement, criminal prosecution and implementation of third-party reporting through the Foreign Account Tax Compliance Act (FATCA).
Loophole:
The IRS also closed a loophole that’s been used by some taxpayers with offshore accounts. Under existing law, if a taxpayer challenges in a foreign court the disclosure of tax information by that government, the taxpayer is required to notify the U.S. Justice Department of the appeal.
The IRS said that if the taxpayer fails to comply with this law and does not notify the U.S. Justice Department of the foreign appeal, the taxpayer will no longer be eligible for the Offshore Voluntary Disclosure Program (OVDP). The IRS also put taxpayers on notice that their eligibility for OVDP could be terminated once the U.S. government has taken action in connection with their specific financial institution.
OVDP
Additional details of these eligibility issues are available in a new set of questions and answers released today on the current OVDP, which was announced in January (see IR-2012-5). The IRS reopened the OVDP following continued strong interest from taxpayers and tax practitioners after the closure of the 2011 and 2009 programs.
This program – which helps bring people back into the tax system — will be open for an indefinite period until otherwise announced. The program is similar to the 2011 program in many ways, but with a few key differences. Unlike last year, there is no set deadline for people to apply. However, the terms of the program could change at any time going forward.
Under the current OVDP, the offshore penalty has been raised to 27.5 percent from 25 percent in the 2011 program. The reduced penalty categories of 5 percent and 12.5 percent are still available.
The IRS also announced a plan to help U.S. citizens residing overseas to catch up with tax filing obligations and assistance for people with foreign retirement plan issues.
by Fresh Start Tax | Jun 25, 2012 | FBAR
FBAR – Tax Attorneys, CPAs, Former IRS – Miami, Ft.Lauderdale, Palm Beaches – IRS Tax Experts 954-492-0088
Hire True FBAR Local Experts!
We are a Professional Tax Firm specializing in FBAR cases and IRS Tax Representation.
We are experts in the field and all information that comes to us is covered under “attorney-client privilege.
We are comprised of Board Certified Tax Attorneys, CPA’s and Former IRS Agents and Managers.
We are staffed with Former IRS Audit Managers as well as Former IRS Appellate Officers. We have a combined 205 years of direct IRS tax experience and over 60 years of working in the local South Florida IRS offices as well as in the district and regional offices.
When employed by the IRS we were teaching Agents that taught Tax Law at the IRS.
What is FBAR?
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.
The tool of FBAR.
The FBAR is a tool to help the United States government identify persons who may be using foreign financial accounts to circumvent United States law. The IRS has been very aggressive in working the FBAR cases because of the large review brought in by these cases.
Federal Investigators use FBARs to help identify or trace funds used for illicit purposes or to identify unreported income maintained or generated abroad.
Foreign Bank and Financial Accounts Report (FBAR) Responsibilities
The Financial Crimes Enforcement Network (FinCEN) today issued a rule that amends the Bank Secrecy Act (BSA) implementing regulations regarding the Report of Foreign Bank and Financial Accounts (FBAR).
FBAR Requirements
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 final rule explains FinCEN’s approach to issues raised in comments submitted in response to the NPRM from tax professionals and industry experts.
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Call us for a free tax consult 1-866-700-1040
FBAR – Tax Attorneys, CPAs, Former IRS – Miami, Ft.Lauderdale, Palm Beaches – IRS Tax Experts – South Florida
