by Fresh Start Tax | Nov 11, 2012 | Back Taxes, Expatriate Tax, FBAR, IRS Representation, IRS Tax Debt, IRS Tax Problem, Tax Lawyer, Tax Returns, Tax Settlements
Australia- FBAR, EXPAT – Attorney, Lawyers, Former IRS – Filing, Penalties, Settlement – Affordable Tax Experts
Do not be bullied by the IRS. Find out the truth about FBAR disclosures to the IRS.
You have options. We can file and settle your case.
Call us today, we are comprised of Board Certified Tax Attorneys, Tax Lawyers, CPA’s and Former IRS Agents, Managers and Instructors. 1-866-700-1040.
We have over 206 years of total tax experience and over 60 years of direct IRS experience in resolving IRS tax issues and tax problems. We are a full service tax firm with all work being done in house by true tax experts.
We are true Tax Experts of FBAR and Expatriate Tax Issues.
There is a great deal on the web and in press releases that has scared many FBAR filers and Expats into taking position on the filing of FBAR that makes one believe that everything must go through Criminal Investigation.
The reality is that few taxpayers are tax criminals. What is so sad it that the IRS has scared everyone to death regarding FBAR.
The truth be told you have the option of making a Silent Disclosure.
Some taxpayers have already made quiet disclosures by filing amended returns.
Before a decision is made on each case, a tax attorney or tax lawyer will use a set of facts particular to that case. There are no two cases the same, each has a unique set of circumstances.
With that said Quiet Disclosure are not for everyone that is why a careful review must be made on each case.
Taxpayers with unreported foreign bank accounts present themselves and their professional advisers with a bunch of very important important decisions they need to make.
These tax and filing decisions must be made based on a very careful review of all material, information, an understanding of the potential tax penalties and interest involved, and the exposure to any other financial crimes, criminal implications or tax penalties.
Regardless of how tempting under no circumstances should Attorneys or Lawyers and taxpayers ignore reporting tax and FBAR tax requirements simply because the IRS has not yet raised the issue in the client’s specific case.
Our rule of thumb, find IRS before they find you.
How the process works.
The IRS does review amended returns and could select any amended return for examination.
If a tax return is selected for examination, the 20 percent offshore penalty would not be available.
Criminal Behavior
When criminal behavior is evident and the disclosure does not meet the requirements of a voluntary disclosure under IRM 9.5.11.9, the IRS may recommend criminal prosecution to the Department of Justice.
Taxpayers who have already made quiet disclosures but have not yet been selected for examination may take advantage of the penalty framework applicable to voluntary disclosure requests regarding unreported offshore accounts and entities, provided they otherwise meet the criteria for voluntary disclosure set forth in IRM 9.5.11.9.
Call us for more detail. 1-866-700-1040. Privileged conversation with a tax attorney or tax lawyers.
What possible forms are needed to be Filed with the IRS ?
Besides federal income tax returns, what forms or other returns must be filed?
The following forms must be filed:
a. Copies of original and amended federal income tax returns for tax periods covered by the voluntary disclosure,
b. Complete and accurate amended federal income tax returns (or original returns, if not previously filed) of the taxpayer for all tax years covered by the voluntary disclosure;
c. An explanation of previously unreported or under reported income or incorrectly claimed deductions or credits related to undisclosed foreign accounts or undisclosed foreign entities, including the reason(s) for the error or omission,
d. If the taxpayer is a decedent’s estate, or is an individual who participated in the failure to report the foreign account or foreign entity in a required gift or estate tax return, either as executor or advisor, complete and accurate amended estate or gift tax returns (original returns, if not previously filed) necessary to correct the under reporting of assets held in or transferred through undisclosed foreign accounts or foreign entities;
Complete and accurate amended information returns required to be filed by the taxpayer, including, but not limited to,
a. Tax Forms 3520,
b. 3520-A,
c. 5471,
d. 5472,
e. 926 and
f. 8865 (or originals, if not previously filed) for all tax years covered by the voluntary disclosure, for which the taxpayer requests relief; and
Complete and accurate Form TD F 90.22-1, Report of Foreign Bank and Financial Accounts, for foreign accounts maintained during calendar years covered by the voluntary disclosure.
Call us today for more details and find you the truth. you do not have to be worried. 1-866-700-1040
by Fresh Start Tax | Jul 5, 2012 | FBAR, IRS Tax Debt, Tax Lawyer
Expatriate Professional Tax Services. We are comprised of Tax Attorneys, CPAs, Former IRS Agents with over 205 years of total professional tax experience and over 60 years of direct work experience at the IRS in the local, district and regional tax office.
We taught Tax Law at the IRS. We are true professional tax experts.
Our firm handles all of tax compliance with our unparalleled tax knowledge of international tax regulations and understanding of the needs of United States citizens living abroad. We offer a full range of professional tax service for all your accounting and IRS needs including tax planning.
Call us today for a no cost professional tax consult. 1-866-700-1040.
Tax Tip regarding Form 8854 – the importance of the filing of this form
What to do if you have not filed a Form 8854?
individual taxpayer(s) that renounced their United States citizenship or terminated their long-term resident status for tax purposes on or before June 3, 2004 must file a Form 8854 to comply with the notification requirements under IRC 877 and 877A.
Furthermore, pursuant to IRC 7701(n), until such individuals both files a Form 8854 with the IRS and notifies either the Department of State or of Homeland Security of their expatriation or termination of long-term resident status for tax purposes, such individuals will continue to be treated as if they were still United States citizens or residents for tax purposes.
With the new modernization program under the new health care program and the hiring of new agents, we can expect to see a huge crack down in this area.
Also, for individuals that expatriated after June 3, 2004, IRC 6039G requires annual information reporting for each taxable year during which such an individual is subject to the rules of IRC 877.
The annual Form 8854 is due on the date that the individual’s U.S. income tax return for the taxable year is due or would be due if such a return were required to be filed.
Ex-Pat – Professional Tax Services – Attorneys, Tax Lawyer , CPAs, Former IRS – Expat Tax Experts- Call for a no cost professional tax consult. 1-866-700-1040.
We also specialize in the filing of back tax returns and tax settlements.
by Fresh Start Tax | Jul 3, 2012 | Expatriate Tax, FBAR, Representation, Tax Lawyer, Tax News, Tax Returns
We are Ex- Pat and FBAR tax specialists. We are tax experts. As Former IRS agents we taught Tax Law at the IRS.
We have successful handled a great deal of both Ex- Pat and FBAR cases.
You can call today for a no cost professional confidential consultation.
We are comprised of Board Certified Tax Attorneys, Lawyers, CPA’s and Former IRS Agents.
We have over 205 years of professional tax experience and over 60 years of direct work experience with the IRS. We worked in the local, district and regional offices of the Internal Revenue Service.
Do you need to file a tax return for the IRS?
Under the new health care plan IRS is coming. The current tax appropriations under the new law is about to let the IRS loose.
Among the various new requirements of the IRS that are 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.
If all your 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 taxpayer will be subject to the IRC 877 and 877A expatriation tax provisions.
Individual(s) that have expatriated should file all tax returns that are due, regardless of whether or not full payment can be made with the return.
Depending on an individual’s circumstances, a taxpayer filing late may qualify for a payment plan.
All payment plans to the IRS require continued compliance with all filing and payment responsibilities after the plan is approved and throughout the course of the plan.
IRS imposes a $10,000 penalty may be imposed for failure to file Form 8854 when required.
IRS is sending notices to expatriates that have not complied with the Form 8854 requirements, including the imposition of the $10,000 penalty where appropriate.
IRS is acquiring lists through tax treaties with and through various countries.
Failure to file or not including all the information required by the form or including incorrect information will result in large penalties.
FBAR REQUIREMENTS
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).
The FBAR is required because foreign financial institutions may not be subject to the same reporting requirements as domestic financial institutions. You should call us if you have questions.
Federal Tax Investigators with the IRS use FBARs to help identify or trace funds used for illicit purposes or to identify unreported income maintained or generated abroad.
It is important to know that the IRS is receiving $500 million dollars in funding under the new health care plan, yes, the new health care plan.
A lot of that budget will be at the expense of Ex-Pats and FBAR
We are EXPAT, FBAR Tax Specialists. Comprised of Tax Attorneys, Lawyers and Former IRS. We are affordable, experienced and will tell you the truth about your case.
