by Fresh Start Tax | Jul 11, 2012 | Expatriate Tax, Tax Lawyer, Tax Returns
We are a Expatriate Tax Experts. We are comprised of Board Certified Tax Attorneys, Tax Lawyers and Former IRS Agents and Managers.
We have over 60 years of direct work experience at the IRS in the local, district and regional offices of the IRS. We taught Tax Law at the IRS.
We true tax experts! We have over 206 years of total tax experience.
Many of the tax issues that arise with Expatriates are the non filing of tax returns and the filing of form 8854.
The following deals with the two major tax issues that the IRS is currently addressing.
If you have not filed a tax return.
Among the various new tax requirements 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. This is a must to file. The IRS will pursue non filers via the new tax software that is being updated in their system. IRS is building special groups within the Service to pursue Expats simply because of the large revenues that are brought in from Expats.
If all 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 will be subject to the IRC 877 and 877A expatriation tax provisions.
Call our Expat Lawyers, Attorneys and Former IRS agents to go over you case for no cost.
Individual taxpayers that have expatriated should file all tax returns that are due, regardless of whether or not full payment can be made with the return. It is most important to file even though you do not have the money. IRS cannot come after you criminally if you file.
Depending on a taxpayers individual’s circumstances, a taxpayer filing late may qualify for a payment plan. Many taxpayers may also qualify for a full abatement of penalties if reasonable cause exists. Expat Lawyers who are skilled in tax law can many times remove all penalties and interest. It is important you find qualified Expat Lawyers and Attorneys who have IRS tax experience.
Payment Plans
You can qualify for a payment plan if you cannot pay the tax in full. All payment plans require continued compliance with all filing and payment responsibilities after the plan is approved.
IRS to send notices to Expats
IRS is starting to send tax notices to expatriates that have not complied with the Form 8854 requirements, including the imposition of the $10,000 penalty where appropriate. The IRS collected over $4.4 billion dollars in the last 3 years and it will continue to work and develop tax systems to aggressively collect monies from Expats.
We can file all your back tax returns, get penalties and interest abated should you qualify and work out a tax settlement.
EXPAT LAWYER – Former IRS, Tax Lawyers – Expatriates Experts, International & Global Tax Firm – Free Consultations
by Fresh Start Tax | Jul 9, 2012 | Back Taxes, Income Tax Preparation, Representation, Tax Help, Tax Lawyer, Tax Returns, Tax Settlements
Back Tax Return – File Back Taxes – Former Local IRS Agents, Miami, Ft.Lauderdale, Palm Beaches – South Florida 954-492-0088
If you have back tax returns you need to file, let former IRS Agents worked on the local South Florida offices get you back in the system worry free.
We have over 60 years of direct work experience right here on the local South Florida IRS offices. We worked as agents, revenue officers, revenue agents and appeals agents.
All our work is done in-house and we are hired by several local South Florida tax professional offices to handle their IRS tax matters
We can file all your back tax returns and settle your case.
We were former Local IRS Agents and Managers, today and we know all the tax policies and settlement procedures.
Contact us today and speak directly to tax attorneys, CPAs, and former IRS agents about your back tax return or unfiled back taxes.
We can go over all the different tax options to help remedy or solve your back tax problem.
While at IRS in South Florida we taught Tax Law.
We can file your back tax return or back taxes and settle your case.
We can file all business and personal income tax returns.
We can file a power of attorney and you will never have to speak to the Internal Revenue Service.
Call us for a no cost professional tax consultation. 954-492-0088
We have over 60 years of direct work experience at the local South Florida IRS. We have been Agents, Managers and Teaching Instructors.
We have resolved several hundred tax cases right here in South Florida. We have been practicing tax resolution and representation of taxpayers right here in South Florida since 1982.
Has the IRS contacted you? Beware of the 6020B
Have you received a tax notice from the Internal Revenue Service asking to file a back tax return(s)?
The IRS can and will file your tax return is you do not respond to tax notices regarding filing back returns.
The IRS has the right to issue a bank levy or wage garnishment levy on back taxes if you do not answer their letters on a timely basis.
You must respond to IRS in a timely manner. IRS has the right to prepare your back tax returns under 6020B of the IRC Code. That means they can prepare your tax return and form a tax assessment against you.
6020B of the IRC – IRS can file your tax return
(1) If the taxpayer fails to file employment, excise and
partnership tax returns by the specified date the
return should be prepared under the authority of IRC
6020(b)
We can file all your back tax returns and settle your back taxes.
We are comprised of Tax Attorneys, Tax Lawyers, CPA’s and Former IRS Agents.
We have prepared thousands of back taxes and tax returns since 1982.
Call us today.954-492-0088
Affordable and Assessable.
Back Tax Return – File Back Taxes – Former Local IRS Agents, Miami, Ft.Lauderdale, Palm Beaches, Keys – All South Florida
by Fresh Start Tax | Jul 7, 2012 | FBAR, Representation, Tax Lawyer, Tax Returns
With the FBAR buzz flying around many questions still surround FBAR itself.
Much has been written and here are some simple answers to common questions asked regarding FBAR requirements.
These Q&A’s help to explain the What, Who and the Where of FBAR.
Should you have other questions regarding FBAR call us today for a no cost professional; tax consultation. 1-866-700-1040.
You will speak directly to Tax Attorneys, Tax Lawyers, CPA’s and Former IRS agents with over 206 years of professional tax experience and over 60 years of direct experience with the IRS.
1. Who Must File an FBAR form?
Some United States persons are required to file an FBAR if:
1. 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
2. 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. Definition per IRS Tax Law.
2. What are the exceptions to the Reporting Requirement of FBAR
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 accounts
10.Trust beneficiaries; and
11.Foreign financial accounts maintained on a United States military banking facility.
You should call our firm for a comprehensive list of questions we will review with you.
Reporting and Filing Information for FBAR
A person who holds a foreign financial account may have a reporting obligation even though the account produces no taxable income.
The FBAR is not filed with the filer’s federal income tax return.
The granting, by the Internal Revenue Service, of an extension to file federal income tax returns does not extend the due date for filing an FBAR. You may not request an extension for filing the FBAR.
The FBAR is an annual report and must be received by the Department of the Treasury in Detroit, MI, at one of the two addresses below, on or before June 30th of the year following the calendar year being reported.
File by mailing the FBAR to:
United States Department of the Treasury
P.O. Box 32621
Detroit, MI 48232-0621
If an express delivery service is required for a timely filed FBAR, address the parcel to:
IRS Enterprise Computing Center
ATTN: CTR Operations Mail room, 4th Floor
985 Michigan Avenue
Detroit, MI 48226
FBAR – What, Who and Where – IRS Tax Experts – Free Advice – Attorneys, Former IRS
by Fresh Start Tax | Jul 6, 2012 | FBAR, Income Tax Preparation, Tax Help, Tax Lawyer, Tax Returns
Have a late FBAR filing?
Call our tax firm for a no cost professional tax consultation. 1-866-700-1040
You can speak directly to a Tax Attorneys, Lawyers, CPAs or Former IRS Agents all who are IRS tax experts.
We have over 206 years of professional tax representation experience and over 60 years of working directly for the IRS. We taught Tax Law.
If you have a late filing of FBAR we can represent you before the IRS so you will never have to speak with the IRS.
We can work out a tax settlement ( offer in compromise ) and look to abate some of the penalties and interest should your filing result in tax.
FBAR is high gear the feds fully plan to make FBAR Reporting a high priority and a target within the IRS because of the success of the program.
Over 33,000 FBAR filers came forward producing $4.4 billion large.
When the Obama Health Care Plan was signed it allowed for the hiring of 15,000 new agents.
IRS has picked out premium targets and Expatiates and FBAR will be two on their high priority lists.
The first question taxpayers ask regarding FBAR is simply,
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.
The Reporting and Filing Information for FBAR
A person(s) who holds a foreign financial account may have a reporting obligation even though the account produces no taxable income.
Checking the appropriate block on FBAR – related federal tax return or information return questions (for example, on Schedule B of Form 1040, the “Other Information” section of Form 1041, Schedule B of Form 1065, and Schedule N of Form 1120) and filing the FBAR, satisfies the account holder’s reporting obligation.
The FBAR is not to be filed with the filer’s federal income tax return.
The granting by the IRS of a tax extension to file federal income tax returns does not extend the due date for filing an FBAR.
You may not request an extension for filing the FBAR.
The FBAR is an annual report and must be received by the Department of the Treasury in Detroit, MI, at one of the two addresses below, on or before June 30th of the year following the calendar year being reported.
File by mailing the FBAR to:
United States Department of the Treasury
P.O. Box 32621
Detroit, MI 48232-0621
If an express delivery service is required for a timely filed FBAR, address the parcel to:
IRS Enterprise Computing Center
ATTN: CTR Operations Mail Room, 4th Floor
985 Michigan Avenue
Detroit, MI 48226
Let us take the fear out of FBAR. Call today for a free tax consult. 1-866-700-1040
FBAR – Late Filing, Settlement, Reduce Penalties – Tax Attorneys, Former IRS – FBAR Tax Experts
by Fresh Start Tax | Jul 5, 2012 | FBAR, Representation, Tax Help, Tax Lawyer, Tax Returns
The FBAR Filing Requirements.
There is much information buzzing around about FBAR. Most taxpayers are completely uninformed regarding FBAR tax issues and filing requirements.
With the IRS now having over $500 Million in new resource money as a result of the Health Care plan, taxpayers need to become aware of FBAR because the IRS will turn a lot of their time and attention to FBAR and the tax issues related to this program because of the huge revenue FBAR has raised.
To date, FBAR has brought in some $4.4 billion large ones with 33,000 filing over the past three years.
As Former IRS Agents, Tax Attorneys, Lawyers and CPA’s we are FBAR and Expatriate tax experts.
We offer a no cost professional tax consultation for FBAR filing consultations.
We can answer all your questions.
Here are some common questions asked of the FBAR filings.
1. What is an FBAR?
An FBAR is a Report of Foreign Bank and Financial Accounts. The form number is TD F 90-22.1
2. 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.
3. What is a foreign country?
A “foreign country” includes all geographical areas outside the United States, the commonwealth of Puerto Rico, the commonwealth of the Northern Mariana Islands, and the territories and possessions of the United States (including Guam, American Samoa, and the United States Virgin Islands).
4. What is a United States person?
“United States person” includes a citizen or resident of the United States, a domestic partnership, a domestic corporation, and a domestic estate or trust. See Announcement 2010-16.
5. Is a single-member LLC, which is a disregarded entity for U.S. tax purposes, a United States person for FBAR purposes?
Yes, the tax rules concerning disregarded entities do not apply with respect to the FBAR reporting requirement. FBARs are required under Title 31, not under any provisions of the Internal Revenue Code.
6. 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.
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.
FBAR Filing Requirement – IRS Tax Representation – Free Advice – FBAR Tax Experts, Attorneys, Former IRS –
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
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