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 | Sep 30, 2012 | Expatriate Tax, FBAR, Tax Lawyer
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.
by Fresh Start Tax | Sep 27, 2012 | Back Taxes, FBAR, Tax Lawyer
We are comprised of Tax Attorneys, Tax Lawyers, CPA’s and Former IRS agents. We have over 205 years of professional tax experience and over 60 years working directly for the IRS.
Why use us? We can take away your worry through our experience at the IRS
We taught Tax Law at the IRS and we are familiar with tax policies and tax settlements.
No cost consults, 1-866-700-1040. We are FBAR and Ex Pat Experts
All the countries are going down like domino’s including Japan.
First it was UBS and yes even Lichtenstein. Nobody thought Lichtenstein.
Liechtenstein finally informed on their Bank Clients on the U.S. Tax Evasion Request to report on certain foreign accounts.
Liechtenstein has told there American clients of the principality’s oldest bank that U.S. authorities have requested their account data as they widen a tax probe for potential tax evasion and potential tax fraud. Investors are scrambling.
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. We have no idea how many accounts are included on this request however the word on the streets, “thousands”.
Many were set up by financial planners and attorneys who are now nervous about the request and investigation.
Liechtenstein facilitated the group request from the U.S. by amending a tax law in March.
Liechtenstein’s second-biggest bank, also known as LLB, is one of 11 financial firms, including Credit Suisse Group AG (CSGN) and Julius Baer Group Ltd. (BAER), being investigated as part of a United States probe of offshore tax evasion.
The stakes for Swiss banks were raised after the Department of Justice indicted Wegelin & Co. on Feb. 2 for allegedly helping customers hide money from the Internal Revenue Service.
The IRS is taking a very aggressive approach to collect monies on FBAR and are funding huge amounts of revenue to go after the deep foreign taxpayers pockets of monies.
IRS results up to this point.
So far the US has been very successful and collected north of $5 Billion large in the first three years of the FBAR Program. The IRS has just been funded another $500,000 million by the Obama administration to beef up the IRS enforcement arm and much of money will be dedicated to non-filers as well as FBAR compliance.
The Progress
Offshore banks must begin complying with the Foreign Account Tax Compliance Act and the Internal Revenue Service has been getting cooperation from other nations. Japan became one of the newest country to pledge its cooperation with the U.S.
The FATCA
FATCA requires foreign banks to disclose the identities of all account holders who are also U.S. taxpayers. In many countries, such disclosure violates that nation’s bank secrecy laws. Banks and financial institution have been caught in the middle. After all, they make loads of money on the clients. However, if the financial institutions do not comply with the IRS requests and the new FATCA law, they will be violating the law.
Most of the developed nations have indicated they will cooperate fearing US reprisal.
That means banks and financial institution in many countries will now have to identify and report Americans holding accounts. The current trend for bank compliance seems to be trending to eliminate the hassle by simply closing foreign accounts.
Japan is the latest country to indicate its willingness to cooperate. That means that U.S. taxpayers with unreported accounts in Japan could soon have IRS tax issues. Foreign accounts are legal, the penalties for not reporting those accounts are very expensive and could include prison time. Find the IRS before they find you.
Foreign bank and financial accounts such as CD’s, brokerage accounts, most retirement accounts must be reported annually to the IRS on Report of Foreign Bank and Financial Account, more commonly known as an FBAR. You can find the Form on our website.
Failure to file FBARs can be criminal and result in penalties of $100,000 or 50% of the highest account balance for each year the account remains undisclosed.
If you have an account in Japan that has not been properly reported call us today to find out your options. 1-866-700-1040. You may want to file a ” quiet disclosure”.
by Fresh Start Tax | Jul 25, 2012 | Christian IRS Tax Relief, Expatriate Tax, FBAR, Tax Lawyer, Tax Settlements
We are a Christian Tax Firm <>< specializing in IRS FBAR and Expatriate Tax Representation.
Call us today for a free Christian tax consult 1-866-700-1040.
We taught Tax Law at the IRS. We know the tax policies and tax procedures because we taught them at the IRS.
We are Biblical Based Christian Tax Firm in all our dealings so expect to hear the truth about your case.
We support Grace FM and Reach FM, Christian Radio.
We are comprised of Board Certified Tax Attorneys, CPA’s and Former IRS Agents, Managers and Instructors.
We have over 206 years of professional tax experience and over 60 years with the Internal Revenue Service.
How do you discern godly counsel?
Psalm 37:30 The godly offer good counsel, they know what is right from wrong.
Proverbs 18:2 Fools have no interest in understanding; they only want to offer their own opinions.
FBAR and Expatriates
With the Federal Government finding over $5.5 billion dollars in Offshore Programs in the last two years, the Fed came out and said it will spend over $500,000 million in new revenue to help catch tax cheats and tax crimes.
What is the FBAR 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. It is best to contact us directly because each case is based on its own merits.
A voluntary disclosure ( VD ) will not automatically guarantee immunity from prosecution; however, a voluntary disclosure may result in prosecution not being recommended. This practice does not apply to taxpayers with illegal source income.This is where we come in. The general rule, contact IRS before they contact you.
A voluntary disclosure occurs when the communication is truthful, timely, complete, and when:
1. the taxpayer shows a willingness to cooperate and does in fact cooperate with the IRS agent in determining his or her correct tax liability,
2. when the taxpayer makes a good faith arrangements with the IRS to pay in full, the tax, interest, and any penalties determined by the IRS to be applicable. Remember it is possible to abate penalties and interest. Honesty goes along way!
3. A full disclosure is timely if it is received before:
a. the IRS has initiated a civil examination or criminal investigation of the taxpayer, or has notified the taxpayer that it intends to commence such an examination or investigation;
b. the IRS has received information from a third party (e.g., informant, other governmental agency, or the media) alerting the IRS to the specific taxpayer’s noncompliance;
c. the IRS has initiated a civil examination or criminal investigation which is directly related to the specific liability of the taxpayer; or
d. the IRS has acquired information directly related to the specific liability of the taxpayer from a criminal enforcement action.
4. Any taxpayer who contacts the IRS in person or through a representative regarding voluntary disclosure will be directed to Criminal Investigation for evaluation of the disclosure.
Call today for a no cost Christian Tax Consult 1-866-700-1040.
FBAR, Christian IRS Tax Problem Help, FBAR, Expatriate, Attorneys, Former IRS, FBAR, Expat – Experts
FBAR, Christian, IRS Tax Help, FBAR, Expatriate, Attorneys, Former IRS, FBAR, Expat Experts
by Fresh Start Tax | Jul 14, 2012 | Back Taxes, Expatriate Tax, Representation, Tax Lawyer, Tax Returns
Before hiring anyone make sure you speak to us somewhere in the process. You can speak directly to Former IRS Agents and Managers who know the complete IRS process and who have worked directly for the IRS for over 60 years.
We are tax experts in Expatriate Tax Returns.
We taught Tax Law at the IRS and know all the tax policies and techniques to get you the best possible results. Expatriate are certainly a tax specialty.
We are accessible and affordable. We will make sure you pay the lowest amount allowed by LAW.
We can file all your income tax returns, back taxes and if you owe money to the IRS we can work out a payment plan and file for abatement of penalties should you qualify.
We have prepared thousands of tax returns since 1982 and we are “A” rated with the BBB.
On staff, Tax Attorneys, CPA’s and Former Agents as previously mentioned. Call us for a no cost consult. 1-866-700-1040. Skype available.
Income Tax Preparation.
Exclusion amounts for tax purposes.
1. The maximum foreign earned income exclusion.
Adjusted annually for inflation. For 2011, the maximum exclusion has increased to $92,900.
2.Housing expenses – Base Amounts
The computation of the base housing amount (line 32 of Form 2555) is tied to the maximum foreign earned income exclusion.
The amount is 16 percent of the exclusion amount (computed on a daily basis), multiplied by the number of days in your qualifying period that fall within your 2011 tax year. For 2011, this amount is $40.72 per day ($14,864 per year).
3. Housing expenses – maximum amounts
The amount of qualified housing expenses eligible for the housing exclusion and housing deduction has changed for some locations.
4. Filing requirements.
The amount of income you can receive before you must file an income tax return has increased. Check with us to make sure.
5. Self-employment tax reduced.
For 2011, the rate of self-employment tax has been reduced from 15.3% to 13.3%.
The maximum amount of net earnings from self-employment that is subject to the social security part of the self-employment tax remains at $106,800.
All net earnings are subject to the Medicare part of the tax.
6. IRA deduction expanded.
You may be able to take an IRA deduction if you were covered by a retirement plan and your 2011 modified adjusted gross income (AGI) is less than $66,000 ($110,000 if married filing jointly or a qualifying widow(er)).
If your spouse was covered by a retirement plan, but you were not, you may be able to take an IRA deduction if your 2011 modified AGI is less than $179,000.
Form 8938. If you had foreign financial assets in 2011, you may have to file new Form 8938 with your return.
7. Change of address. If you change your home mailing address, notify the Internal Revenue Service using Form 8822, Change of Address. If you are changing your business address, use Form 8822-B, Change of Address—Business.
If you are a Expatriate, Expat, and need to file tax returns or many years back taxes call us for a no cost consult. 1-866-700-1040.
Expatriate Tax Returns, Filing Back Taxes – Former IRS, Attorneys, IRS Expat Experts – Free Tax Consultation – Income Tax Prep
