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.
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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.
by Fresh Start Tax | Jul 21, 2012 | Tax Help, Tax Lawyer
If you need IRS seizure Help call us today. Let former IRS Agents and Managers take the pressure and worry off your back.
Free consultations. 1-866-700-1040.
IRS make 747 Seizures a year. IRS threatens so much and their bite is not as big as there bark.
Whether it is in the ASC Unit or at the local IRS level through Revenue Officers the truth of the matter, IRS does not seize very much.
If you do the math, IRS makes about 14 seizures a year in each state per year.
Fear drives the taxpayers to settle with the IRS.
Why are more seizure not made?
The truth of the matter is that IRS fears public outcry and fear of making a mistake. Everyone must cover their asses and a wrong seizure could put you in deep woods as an Agents or a Managers. Plus everyone in the world at the IRS must sign off.
Also, it takes so much documentation the local Agents just does not want to be involved in this time consuming project.
Cases that IRS does seize on.
IRS will tend to seize in habitual delinquents and tax abusers. Those repeated offenders that just to do not care. You must really piss the IRS off before a seizure is made.
Also, you have so many appeal rights, the seizure may never be recommended or your appeal will usually over turn the seizure.
If the IRS is threatening seizure call us today for immediate help. We are IRS tax experts.
by Fresh Start Tax | Jul 20, 2012 | FBAR, Representation, Tax Lawyer, Tax Returns, Tax Settlements
FBAR – Tax Attorneys, Experts in FBAR Representation – Filing, Negotiation, Settlements Former IRS.
Free Tax Consults 1-866-700-1040
We are FBAR Tax Experts. We we staffed with Tax Attorneys, Lawyers, CPA’s and Former IRS agents who have 60 years of direct work experience at the IRS in the local, district and regional offices of the IRS.
We have a total of 205 years of professional tax experience in all areas of the IRS including FBAR Representation, FBAR Filing, FBAR Negotiations, FBAR Tax Audits, FBAR Settlements,
FBAR and what you need to know.
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). With Foreign Financial Instructions now reporting to the IRS it is critical to follow up and file your FBAR 90-22.1
The FBAR is required because foreign financial institutions are not usually subject to the same reporting requirements as domestic financial institutions.
The FBAR is a tool to help the United States government identify persons who may be using foreign financial accounts to circumvent, hide, evade or deceive with criminal intent the United States Tax Laws.
The FBAR Program to date has yielded the Federal Government over $5 Billion when over 33,000 persons came forward.
Our Tax Attorneys who are experts in RBAR Representation can steer you away from trouble and worry.
Common Questions ask regarding FBAR.
What happens if an account holder is required to file an FBAR and fails to do so?
The failure to file an FBAR when required to do so can potentially result in civil penalties, criminal penalties or both. If you learn you were required to file FBARs for earlier years, you should file the delinquent FBAR reports and attach a statement explaining why the reports are filed late.
No penalty will be asserted if the IRS determines that the late filings were due to reasonable cause. Keep copies of what you send for your records.
Can cumulative FBAR penalties exceed the amount in a taxpayer’s foreign accounts?
May civil penalties be assessed?
Yes, under the penalty provisions found in 31 U.S.C. 5314(a)(5), it is possible to assert civil penalties for FBAR violations in amounts that exceed the balance in the foreign financial account.
How long should account holders retain records of the foreign accounts?
Records of accounts required to be reported on an FBAR must be retained for a period of five years. Failure to maintain required records may result in civil penalties, criminal penalties or both.
FBAR, Tax Attorneys, Experts in FBAR Representation, Filing, Negotiation, Settlements, Former IRS
by Fresh Start Tax | Jul 20, 2012 | FBAR, Tax Lawyer
The word FBAR brings some sort of fear out of people. Yes it is a four letter word but we can help take the fear and worry out of FBAR.
We are an affordable tax specialty firm.
We are comprised of Board Certified Tax Attorneys, Tax Lawyers, CPA’s and Former IRS Agents who were Managers and Former IRS instructors who taught Tax Law at the IRS.
We are IRS Tax Experts in FBAR. You may call us for a no cost professional tax consultation at 1-866-700-1040. You will speak directly to a tax professional. You will hear the truth and ways to alleviate your fears and worries. All calls can be made if requested under attorney-client privilege.
Why so much information about FBAR of late.
Once the Feds were able to get information from Swiss Financial and Banking institutions the US government found a huge amount of undisclosed monies. Billions and billions of dollars have seemed to go unreported and untaxed.
After the Swiss gave way so to did other countries from US pressure. The IRS has and is putting tax treaties in place to get a firm handle on this international market to collect all dollars it has coming in as revenue to its coffers. IRS is in a ruthless pursuit to catch tax cheats.
IRS has offered two programs thus far and has collected thru FBAR reporting over $5 Billion in tax and penalties. FBAR has made a big hit with the Congress. It is a pure revenue generator without taxation.
The fear of criminal prosecution and large fines have drove 33,000 taxpayers forward to file and pay large FBAR fines.
If you have a situation or a potential problem and you would like to speak about regarding FBAR or other issues, please call our Tax Attorneys, Tax Lawyers or Former IRS agents for a free consultation. Skype available.
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?
A. 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.
FBAR ATTORNEY, – Former IRS, Tax Attorney, Lawyers, FBAR EXPERTS, “A” Plus Rated
by Fresh Start Tax | Jul 19, 2012 | FBAR, Tax Help, Tax Lawyer, Tax Settlements
FBAR Penalties – IRS Tax Help – Owe Back Taxes, Settle – Former IRS, Tax Attorneys, Lawyers – FBAR Experts 1-866-700-1040
We are FBAR tax experts that can solve your tax problems.
We are comprised of Tax Attorneys, Tax Lawyers, CPA’s and Former IRS Agents.
We taught Tax Law at the IRS. We know the procedures and policies.
We have over 60 years with the IRS and over 205 years of professional tax experience.
We can help get rid of or abate penalties and interest, provide solid tax help advice, and help settle any back tax issues you may have. We are affordable.
You may call us for a no cost professional tax consult. 1-866-700-1040
FBAR Penalties, Reasonable Cause
Whether a failure to file or failure to pay is due to reasonable cause is based on a consideration of the facts and circumstances. Each case is very different.
IRS reasonable cause relief is generally granted by the IRS when you demonstrate that you exercised ordinary business care and prudence in meeting your tax obligations but nevertheless failed to meet them.
Documentation is a key criteria.
In determining whether you exercised ordinary business care and prudence, the IRS will consider all available information, including but not limited to :
1. The reasons given for not meeting your tax obligations;
2.Your compliance history;
3. The length of time between your failure to meet your tax obligations and your 4.Subsequent compliance; and
5.Circumstances beyond your control.
IRS reasonable cause may be established if you show that you were not aware of specific obligations to file returns or pay taxes, depending on the facts and circumstances of your case.
Among other of facts and circumstances that will be considered by the IRS are:
1. Your education;
2.Whether you have previously been subject to the tax;
3. Whether you have been penalized before;
4.Whether there were recent changes in the tax forms or law that you could not reasonably be expected to know; and
5. The level of complexity of a tax or compliance issue.
You may have reasonable cause for noncompliance due to ignorance of the law if a reasonable and good faith effort was made to comply with the law or you were unaware of the requirement and could not reasonably be expected to know of the requirement.
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