We have over 206 years of combined IRS tax experience and over 60 years of working directly for the Internal Revenue Service in the local, district and regional offices of the IRS.
Why chose us.
We can take the fear of FBAR and overseas issue away from individual because of our vast knowledge and experience at the IRS. We taught Tax Law at the IRS and understand their tax policies and settlement strategies.
The Offshore Voluntary Disclosure Program.
You have two options.
1. You can opt in to the voluntary disclosure or,
2.Consider the “quiet disclosure.
You should call us directly to find out which program is best for you. Each case and fact pattern is different and after we hear all the facts we can make a determination and give you a recommendation which of the options best suits your needs.
The Internal Revenue Service voluntary disclosure is a program in which all filing go directly through IRS.
So far the IRS has had total collections of more than $4.4 billion so far from the two previous international programs.
The third offshore program comes as the IRS continues working on a wide range of international tax issues and follows ongoing efforts with the Justice Department to pursue criminal prosecution of international tax evasion. This program will be open for an indefinite period until otherwise announced.
After the third offshore effort, the IRS has collected $3.4 billion so far from people who participated in the 2009 offshore program, reflecting closures of about 95 percent of the cases from the 2009 program. On top of that, the IRS has collected an additional $1 billion from up front payments required under the 2011 program. That number will grow as the IRS processes the 2011 cases.
In all, the IRS has seen 33,000 voluntary disclosures from the 2009 and 2011 offshore initiatives. Since the 2011 program closed last September, hundreds of taxpayers have come forward to make voluntary disclosures.
The Penalty Structure
The overall penalty structure for the new program is the same for 2011, except for taxpayers in the highest penalty category.
For the new program, the penalty framework requires individuals to pay a penalty of 27.5 percent of the highest aggregate balance in foreign bank accounts/entities or value of foreign assets during the eight full tax years prior to the disclosure.
That is up from 25 percent in the 2011 program. Some taxpayers will be eligible for 5 or 12.5 percent penalties; these remain the same in the new program as in 2011.
Participants must file all original and amended tax returns and include payment for back-taxes and interest for up to eight years as well as paying accuracy-related and/or delinquency penalties.
Participants face a 27.5 percent penalty, but taxpayers in limited situations can qualify for a 5 percent penalty. Smaller offshore accounts will face a 12.5 percent penalty.
Exception $75,000
People whose offshore accounts or assets did not surpass $75,000 in any calendar year covered by the new OVDP will qualify for this lower rate. As under the prior programs, taxpayers who feel that the penalty is disproportionate may opt instead to be examined.
The IRS recognizes that its success in offshore enforcement and in the disclosure programs has raised awareness related to tax filing obligations.
This includes awareness by dual citizens and others who may be delinquent in filing, but owe no U.S. tax.
The IRS is currently developing procedures by which these taxpayers may come into compliance with U.S. tax law. The IRS is also committed to educating all taxpayers so that they understand their U.S. tax responsibilities.
Call us today and to learn more and speak directly to a Tax Attorney, Tax Lawyer or Former IRS. We can stop the worry today.
