We are comprised of FBAR tax experts. On staff, Board Certified Tax Attorneys, Tax Lawyers, CPA’s and Former IRS agents, managers and instructors.
We have a total of 205 years of professional tax experience and 60 years of working directly for the IRS in the local, district and regional offices of the IRS.
We are FBAR and Overseas tax matters experts.
We taught Tax Law.
For a free tax consultation call 1-866-700-1040 and speak directly to the tax professional that could be working your case today. Stop the worry!
FBAR is the new found fear among taxpayers and individual with foreign bank accounts. However much of that fear can be minimized with seeking solid professional tax help with FBAR and IRS tax experts in civil and criminal tax matters.
UBS account holders certainly have the added stomach knots as a result of UBS turning over the account holder information and records to the US government agencies.
The questions we are asked many times by UBS holders is this,
“Are UBS account holders still eligible for the Voluntary Disclosure Practice?”
The answer is YES!
There is a standard Voluntary Disclosure Practice that applies to everyone including USB Account holders.
This is the general IRS Voluntary Disclosure Practice.
It is currently the practice of the IRS that a voluntary disclosure will be considered along with all other factors in the investigation in determining whether criminal prosecution will be recommended.
This voluntary disclosure practice creates no substantive or procedural rights for taxpayers, but rather is a matter of internal IRS practice, provided solely for guidance to IRS personnel.
As a general rule, if you contact IRS first your problems are significantly minimize.
Taxpayers cannot rely on the fact that other similarly situated taxpayers may not have been recommended for criminal prosecution.
A voluntary disclosure will not automatically guarantee immunity from prosecution however a voluntary disclosure may result in prosecution not being recommended.
This practice usually does not apply to taxpayers with illegal source income such as terrorism or drug activity.
A voluntary disclosure occurs when the communication is truthful, timely, complete, thorough and when;
1. the taxpayer shows a willingness to cooperate (and does in fact cooperate) with the IRS in determining his or her correct tax liability; and
2. the taxpayer makes good faith arrangements with the IRS to pay in full, the tax, interest, and any penalties determined by the IRS to be applicable.
The Penalty Framework
How does the penalty framework work? Can you give us an example?
A12. Assume the taxpayer has the following amounts in a foreign account over a period of six years. Although the amount on deposit may have been in the account for many years, it is assumed for purposes of the example that it is not unreported income in 2003.
|
Year |
Amount on Deposit |
Interest Income |
Account Balance |
|
2003 |
$1,000,000 |
$50,000 |
$1,050,000 |
|
2004 |
$50,000 |
$1,100,000 |
|
|
2005 |
$50,000 |
$1,150,000 |
|
|
2006 |
$50,000 |
$1,200,000 |
|
|
2007 |
$50,000 |
$1,250,000 |
|
|
2008 |
$50,000 |
$1,300,000 |
(NOTE: This example does not provide for compounded interest, and assumes the taxpayer is in the 35-percent tax bracket, files a return but does not include the foreign account or the interest income on the return, and the maximum applicable penalties are imposed.)
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