by Fresh Start Tax | Sep 30, 2012 | Back Taxes, Expatriate Tax, FBAR, Tax Lawyer, Tax Returns
If you are a US citizen living in Singapore or the surrounding region and have issues regarding FBAR or Expatiate questions, call us today so we can help with any tax issue or potential tax problems you may have. 1-866-700-1040.
We can relieve your worry today. We are FBAR and Expatiate Tax Experts and have over 206 years of total tax experience and we have over 60 combined years with the IRS in the local, district and regional offices of the IRS.
FBAR filing requirement
For those of you have have a FBAR requirement, that is you are required to file FBAR because you had 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 you 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), call us today to find out if this requirement applies to you.
What are the terms of the 2011 Offshore Voluntary Disclosure Initiative?
Under the terms of the 2011 Offshore Voluntary Disclosure Initiative, taxpayers must:
1. The taxpayer must provide copies of previously filed original (and, if applicable, previously filed amended) federal income tax returns for tax years covered by the voluntary disclosure;
2. The taxpayer must provide complete and accurate amended federal income tax returns (for individuals, Form 1040X, or original Form 1040 if delinquent) for all tax years covered by the voluntary disclosure, with applicable schedules detailing the amount and type of previously unreported income from the account or entity (e.g., Schedule B for interest and dividends, Schedule D for capital gains and losses, Schedule E for income from partnerships, S corporations, estates or trusts).
3. The taxpayers must file complete and accurate original or amended offshore-related information returns (see FAQ 29 for certain dissolved entities) and Form TD F 90-22.1 (Report of Foreign Bank and Financial Accounts, commonly known as an “FBAR”) for calendar years 2003 through 2010;
4.Cooperate in the voluntary disclosure process, including providing information on offshore financial accounts, institutions and facilitators, and signing agreements to extend the period of time for assessing tax and penalties;
5. The taxpayer must pay 20% accuracy-related penalties under IRC § 6662(a) on the full amount of your underpayments of tax for all years;
6. The taxpayers must pay failure to file penalties under IRC § 6651(a)(1), if applicable;
7. The taxpayers must pay failure to pay penalties under IRC § 6651(a)(2), if applicable;
8. The taxpayer must pay, in lieu of all other penalties that may apply, including FBAR and offshore-related information return penalties, a miscellaneous Title 26 offshore penalty, equal to 25% (or in limited cases 12.5% (see FAQ 53) or 5% (see FAQ 52)) of the highest aggregate balance in foreign bank accounts/entities or value of foreign assets during the period covered by the voluntary disclosure;
9. The taxpayers must submit full payment of all tax, interest, accuracy-related penalty, and, if applicable, the failure to file and failure to pay penalties with the required submissions set forth by code.
10. The taxpayer must execute a Closing Agreement on Final Determination Covering Specific Matters, Form 906.
You also have another option that you want to hear and know more about.
You have the ability to make a quiet disclosure by filing amended tax returns without notifying IRS. Call us today to find out more and speak directly to a Tax Attorney or Tax Lawyer. 1-866-700-1040. This is called a quiet disclosure.
by Fresh Start Tax | Sep 27, 2012 | Expatriate Tax, FBAR, Tax Lawyer
We are FBAR & Expatriate Tax Experts. We are comprised of Tax Attorneys, Tax Lawyers, Former IRS Agents who have over 205 years of professional tax experience and over 60 years of working directly for the IRS.
We can file FBAR reports, amended tax returns and work out a tax settlement.
Free tax consults. 1-866-700-1040.
Stop the worry today. We are a different tax firm from most because we taught tax law at the IRS and know the system and tax policies.
Important news for those living in Greece, Cyprus and the surrounding areas.
The latest news that came out of Lichtenstein regarding FBAR was not a good sign for taxpayers who need to file FBAR and amended tax returns.
Earlier this year Liechtenstein finally informed on their Bank Clients on the U.S. Tax Evasion Request. Lichtenstein was a haven for taxpayers to hide there monies out of the long arm of the IRS and the US government. Uncle Sam won and is pressing on to bigger targets.
The US Government Request of Records.
Request of records were made by the US government of the Bank accounts at’ Liechtensteinische Landesbank AG (LLB)” that contained at least $500,000 at any time since the beginning of 2004 are covered by the information request, according to a May 30 letter sent to a client by the principality’s tax authority.
The US also announced that in the Liechtenstein group request, U.S. authorities are also targeting lawyers, accountants, financial advisers, asset managers and those responsible for professional “asset protection,” who “conspired with a U.S. taxpayer to commit U.S. crimes or provided assistance,” according to the letter.
IRS is continuing to amass more information and pursue more people internationally, the risk to individuals hiding assets offshore is increasing.
Our advice, file before IRS finds you! We can limit your exposure today.
Some of the areas that IRS announced initiatives were in Greece, Cyprus, Dubai , Hong Kong and Japan. The long arm of the IRS will be making its way soon.
The IRS collected over $5 Billion big ones as a result of the first two FBAR initiatives and the IRS already knows were to hunt. The fear of criminal prosecution looms large.
IRS wants to give those hiding money in foreign accounts a tough, fair way to resolve their tax problems once and for all. And it gives people a chance to come in before IRS find you.
The goal of the Internal Revenue Service is to get people back into the U.S. tax system. Criminal investigators and Revenue Agents are teaming up to combat international tax evasion. New Government Divisions are being set up to make this a top priority for the IRS.
IRS also has additional cases and banks under review. The situation will just get worse in the months ahead for those hiding assets and income offshore.
IRS is even so bold as to post all FBAR victories including prison sentences on their website.
We have successfully handled a number of FBAR cases and we can take the fear and worry away. Call us today. 1-866-700-1040.
FBAR, Greece, Cyprus, Unfiled, Late FBAR , Tax Attorney Lawyers, Former IRS , Representation, Civil & Criminal , Expatriate Help
by Fresh Start Tax | Sep 25, 2012 | FBAR, IRS Tax Problem, Representation, Tax Lawyer
We are a World Wide Tax Firm specializing in FBAR, Offshore and Overseas IRS tax issues, tax resolution and IRS negotiation.
We have a number of current clients in China and are familiar with the tax issues and concerns of those U.S. citizens living in China and the surrounding areas.
The long hand of the US Government including the IRS is reaching into the pockets of those taxpayers world wide including those living in China required to pay taxes on foreign earnings.
Over the past 3 years the IRS has collected over $5 billion dollars from 33,000 taxpayers who have come forward to report earnings from overseas accounts.
The IRS knows this is just the tip of the iceberg and with the hiring many new Revenue Agents, the IRS will be on the hunt for more tax dollars, and yes be sure, IRS can always hold over the heads of taxpayers the fear of a criminal tribunal and prison sentences.
Most taxpayers will have little to fear, but for those who have civil and or criminal problems we are here to help file and report.
We can help answer any questions you may have regarding any civil or potential criminal tax matters of issues.
Who is required to File and Report – FBAR
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). Call us for any questions. 1-866-700-1040.
The FBAR is required because foreign banks as well as financial institutions may not be subject to the same reporting requirements as domestic financial institutions. you must check with each country and institution.
The FBAR is a tool to help the Internal Revenue Service and the United States government identify persons who may be using foreign financial accounts or financial institutions to evade United States Law.
Tax Investigators such as IRS Revenue Agents and Criminal Investigators use FBARs to help identify or trace funds used for illicit purposes such as concealment, terrorism, drug dealings etc to identify unreported income maintained or generated abroad.
Why should taxpayers make a voluntary disclosure.
Taxpayers with undisclosed foreign accounts in financial institutions or entities should make a voluntary disclosure because it is the law and that enables them to become compliant, avoid substantial civil penalties and generally eliminate the risk of criminal prosecution which is tremendous leverage..
Making a” voluntary disclosure” to the US Government also provides the opportunity to calculate, with a reasonable degree of certainty, the total cost of resolving all offshore tax issues including penalties and interest.
Taxpayers who do not submit a voluntary disclosure ( VD ) 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 remains actively engaged in rooting out the identities of those with undisclosed foreign accounts. Moreover, increasingly this information is available to the IRS under tax treaties, through submissions by whistle blowers, and will become more available as the Foreign Account Tax Compliance Act (FATCA) and Foreign Financial Asset Reporting very become effective.
Each taxpayers situation is unique different. There are no two cases the same. You should seek professional representation in dealing with these issues. Call us today and speak to us under attorney-client privileged. We are affordable, friendly and trustworthy
CHINA, FBAR Filing, Reporting , U.S. Tax Attorneys, Former IRS, FBAR Experts , Civil & Criminal, Affordable, FBAR Tax Experts
by Fresh Start Tax | Sep 1, 2012 | FBAR, Tax Lawyer
Find the IRS before they find you.
After 38 years of professional IRS tax experience that is my best advice to you.
If you need FBAR & Voluntary Disclosure help call Fresh Start Tax LLC and speak directly to Tax Lawyers, Tax Attorneys, Former IRS – FBAR Tax Representation
Call today for a no cost professional tax consultation. 1-866-700-1040.
With much in the news about FBAR and Voluntary Disclosure, there are some very common questions asked.
Within the advent of UBS and FBAR the IRS has been hopped up about bringing into tax compliance offshore monies that have not been reported to the feds. Yes, IRS will make these cases federal investigations because of the huge scale of revenue that is brought in through FBAR alone. IRS received over the past three years over $5 billion.
IRS has found the pot of gold and the pursuit is expected to be ramped up even more in the upcoming years.
Voluntary Disclosures
Why you should make a voluntary disclosure.
Taxpayers or individuals with undisclosed foreign accounts or entities should make a voluntary disclosure ( VD ) because it allows them to become tax compliant, avoid substantial civil penalties and generally eliminate the risk of criminal prosecution.In cases of extreme willfulness this may not be the case.
Talk to us if you fall in this categorize. Believe this criminal prosecution element, the FEAR of IRS should be enough to make sure you do the correct thing. IRS posts the criminal violators on their website. Go to IRS.gov
Getting professional tax help will assure you the very best possible results, the avoiding of criminal prosecution and the reduction of penalties and interest.
Making a voluntary disclosure also provides the opportunity to calculate with a reasonable degree of certainty the total cost of resolving all offshore tax issues.
You may not like what you hear however you must be tax compliant.
Taxpayers ( individuals ) 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.
What is the IRS’s Voluntary Disclosure Practice? ( VDP )
The Voluntary Disclosure Practice is a longstanding practice of IRS Criminal Investigation ( CI ) 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. There are specific code sections that deal with these matters.
When a taxpayer truthfully, timely, and completely complies with all provisions of the voluntary disclosure practice, the IRS will usually not recommend criminal prosecution to the Department of Justice.
Remember, find IRS before they find you.
What form should my voluntary disclosure take?
You may either contact the nearest Special Agent in Charge, ( each office has there won special agent for this matter ) IRS Criminal Investigation, stating that you wish to make a voluntary disclosure, or provide a letter outlining information needed to assist the IRS in determining your acceptance into the voluntary disclosure program. a word of caution here, do this with retention of a tax attorney, tax lawyer or former IRS agent who knows the system. Do not be foolish.
Call us today to find out more details. 1-866-700-1040.
FBAR & Voluntary Disclosure, Tax Lawyers, Tax Attorneys, Former IRS, FBAR Tax Representation
by Fresh Start Tax | Aug 31, 2012 | FBAR, Representation, Tax Lawyer
Use Former IRS Agents and Appeals Officers to abate your FBAR penalties and interest.
Call us today for a no cost consult. 1-866-700-1040
What happens if an account holder is required to file an FBAR and fails to do so?
Failure to file an FBAR when required to do so may potentially result in civil penalties, criminal penalties or both. There is no two cases the same.
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.It is best to hire or consult a FBAR expert.
No penalty will be asserted if the IRS determines that the late filings were due to reasonable cause.
There are numerous reasons that IRS will allow taxpayers to abate both penalties and interest. More can be found on our website. Go to the homepage.
Reasonable Cause for Late FBAR
Whether a failure to file or failure to pay is due to a reasonable cause is based on a consideration of the facts and circumstances of each unique case.
Reasonable cause relief is granted by the IRS when a taxpayer demonstrates that they used exercised ordinary business care and prudence in meeting your tax obligations but nevertheless failed to meet them.
In the abatement of penalties and interest, determining whether you exercised ordinary business care and prudence, the IRS will consider all available information,
1. The reasons given for not meeting your tax obligations,
2. Your compliance history with the IRS,
3. The length of time between your failure to meet your tax obligations and your subsequent compliance, IRS will want to see you took immediate steps to correct the action,
4. Documented circumstances beyond your control.
FBAR 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. Among the facts and circumstances that IRS will considered are:
a. Your education level, the higher the level the lesser the chance,
b. Whether or not you have previously been subject to the tax,
c. Whether you have been penalized by the IRS before,
d. Whether there were recent changes in the tax forms or law that you could not reasonably be expected to know about,
e. The level of complexity of a tax or compliance issue,
f. Reliance upon the advice of a professional tax adviser who was informed of the existence of the foreign financial account and the tax laws that apply,
g. Evidence that the foreign account was established for a legitimate purpose,
h. Evidence that there was no effort to intentionally conceal the reporting of income or assets.
As a general rule, Ignorance of the Law, if reasonable, along with a good faith effort to comply with the law if you could not reasonable be expected to know of the FBAR requirement.
As Former IRS agents there are many other compelling facts and factors for late FBAR Filing relief.
Call us today to find out the truth. 1-866-700-1040.
