We are asked on a routine basis is there after FBAR amnesty?
The answer flat out is NO!
There is no such program being offered by the federal government that would give a taxpayer a free ride.
The best deal you are you will get with the Internal Revenue Service is by hiring a highly trained and experienced tax professional who knows the ropes through the system and there are many of these tax professionals that exist. IRS is very tough on FBAR.
In the last three filing years they have collected over $5.5 billion on Fbar alone. It is a hot ticket item with the IRS and it not going to stop.
I have read that there is an estimate of over $300 billion still to collect.
Make sure you do your due diligence before engaging in a tax firm.
With that said, there is much at you can do about the abatement of penalties and interest as a result of the government computations of the various penalties that arise from the filing and reporting of Fbar.
You should contact us today for a free initial tax consultation and find out the truth about your particular situation. Let our years with the federal government and extensive work experience  be your best friend.
We have been in private practice since 1982 and have over 206 years of professional tax experience.
We are A+ rated by the Better Business Bureau.
We are comprised of tax attorneys, tax lawyers, former IRS agents, managers and tax instructors.
We have over 60 years of working directly for the Internal Revenue Service in a local, district, and regional tax offices of the Internal Revenue Service.
As a result of our years of experience, we know all the protocols, all the formulas, and all the penalty abatement reasonable classes that can serve you well for the situation that you may be now facing
 
Reasonable Cause Guidelines
Reasonable Cause.
Once IRS tax examiners determine that the taxpayer is in full compliance for all open years (not on extension) with respective provisions of the law, they must consider any reason a taxpayer provides in conjunction with the guidelines, principles and evaluating factors relating to reasonable cause based on the facts and circumstances.
IRS Tax Examiners are mindful of the fact that generally these penalties apply to individuals who have business or investment activities in foreign countries, and, as such, general care and prudence requires researching the filing and tax obligations of all jurisdictions.
Reasonable cause does not apply to the initial penalty in some IRC sections.
Many of the penalty sections have specific provisions for reasonable cause.
IRS Tax Examiners must issue a determination letter if the taxpayer requested reasonable cause consideration and it was denied.
Reasonable cause determinations can only be made by the unit that asserted the penalty e.g., campus cannot allow reasonable cause for a penalty asserted by LB&I, TE/GE, or SB/SE Field Office Examination.
A taxpayer’s repeated failure to file does not support testimony that the taxpayer demonstrated normal business care or prudence for the older, late-filed years.
Once all open periods (not on extension) are secured, examiners can make a determination as to reasonable cause for any of the periods not timely filed.
IRM 20.1.1.3.2.1 lists the standards and authorities for establishing reasonable cause and IRM 20.1.1.3.2.2 defines ordinary business care and prudence.
A taxpayer’s testimony that records were not available year after year has no merit. Once all late filings are secured, examiners can make a determination as to any reasonable cause for all periods secured.
IRM 20.1.1.3.2.2.3 provides criteria for taxpayers unable to obtain records.
It is critical to understand that there are no two cases alike.
Facts and circumstances different from taxpayer to taxpayer and many times a taxpayers history will determine the IRS tolerance in certain situations.
Remember there is no such thing as Fbar amnesty at this current time.
 
Avoidance Criminal Prosecution
To avoid criminal prosecution your case must be reviewed by an experienced tax attorney or tax lawyer who has extensive experience in working with the Internal Revenue Service. In all honesty there are no two cases the same.
Every case must be thoroughly reviewed before guidance can be given.
As a general rule, the IRS is going to go after high dollar cases and those who have repeatedly violated the law and have made every effort possible to hide or fail to disclose the funds.
When you call our office and you have such a case, you will speak to a tax attorney or tax lawyer in which all conversations will be held under attorney-client privilege.
 
FBAR Amnesty – Avoidance Criminal Prosecution – Affordable Attorneys, Lawyers, Former IRS