by Fresh Start Tax | Jul 24, 2012 | FBAR, Tax Lawyer
We are a a professional tax firm that specializes in all IRS tax matters and FBAR case matters.
You may contact us for a free consultation and speak directly to a Tax Lawyer that is an expert in FBAR. 1-866-700-1040.
We are fair, honest and will tell you the truth about your FBAR matter. We can take away the worry and fear from any anxiety you may be feeling. You will never have to speak to the Internal Revenue Service. Our Tax Lawyers are excellent.
Do not feel threatened by the IRS, let our years of IRS tax experience work for you.
We have over 206 years of professional tax experience and over 60 years of working directly for the IRS in the local, regional and district offices including teaching tax law at the IRS.
Voluntary Disclosure for FBAR
Two of the most asked questions are found below. Should you have any questions please call us regarding these questions or others you may have.
Why should I make a voluntary disclosure?
Taxpayers with undisclosed foreign accounts or entities should make a voluntary disclosure because it enables them to become compliant, avoid substantial civil penalties and generally eliminate the risk of criminal prosecution.
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.
Taxpayers 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?
The Voluntary Disclosure Practice is a longstanding practice of IRS Criminal Investigation 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. IRS is just beginning to ramp up future enforcement and has a budget of $500 Million additional set for this year alone.
It enables non-compliant taxpayers to resolve their tax liabilities and minimize their chances of criminal prosecution.
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.
Call us to walk you thru this process. 1-866-700-1040.
FBAR , Lawyers, Former IRS, FBAR Specialist, Affordable, FBAR Experts
by Fresh Start Tax | Jul 19, 2012 | FBAR, Tax Help, Tax Lawyer, Tax Settlements
FBAR Penalties – IRS Tax Help – Owe Back Taxes, Settle – Former IRS, Tax Attorneys, Lawyers – FBAR Experts 1-866-700-1040
We are FBAR tax experts that can solve your tax problems.
We are comprised of Tax Attorneys, Tax Lawyers, CPA’s and Former IRS Agents.
We taught Tax Law at the IRS. We know the procedures and policies.
We have over 60 years with the IRS and over 205 years of professional tax experience.
We can help get rid of or abate penalties and interest, provide solid tax help advice, and help settle any back tax issues you may have. We are affordable.
You may call us for a no cost professional tax consult. 1-866-700-1040
FBAR Penalties, Reasonable Cause
Whether a failure to file or failure to pay is due to reasonable cause is based on a consideration of the facts and circumstances. Each case is very different.
IRS reasonable cause relief is generally granted by the IRS when you demonstrate that you exercised ordinary business care and prudence in meeting your tax obligations but nevertheless failed to meet them.
Documentation is a key criteria.
In determining whether you exercised ordinary business care and prudence, the IRS will consider all available information, including but not limited to :
1. The reasons given for not meeting your tax obligations;
2.Your compliance history;
3. The length of time between your failure to meet your tax obligations and your 4.Subsequent compliance; and
5.Circumstances beyond your control.
IRS 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 of your case.
Among other of facts and circumstances that will be considered by the IRS are:
1. Your education;
2.Whether you have previously been subject to the tax;
3. Whether you have been penalized before;
4.Whether there were recent changes in the tax forms or law that you could not reasonably be expected to know; and
5. The level of complexity of a tax or compliance issue.
You may have reasonable cause for noncompliance due to ignorance of the law if a reasonable and good faith effort was made to comply with the law or you were unaware of the requirement and could not reasonably be expected to know of the requirement.
FBAR Penalties, IRS Tax Help, Owe Back Taxes, Settle, Former IRS, Tax Attorneys, Lawyers, FBAR Experts
by Fresh Start Tax | Jul 11, 2012 | Expatriate Tax, Tax Lawyer, Tax Returns
We are a Expatriate Tax Experts. We are comprised of Board Certified Tax Attorneys, Tax Lawyers and Former IRS Agents and Managers.
We have over 60 years of direct work experience at the IRS in the local, district and regional offices of the IRS. We taught Tax Law at the IRS.
We true tax experts! We have over 206 years of total tax experience.
Many of the tax issues that arise with Expatriates are the non filing of tax returns and the filing of form 8854.
The following deals with the two major tax issues that the IRS is currently addressing.
If you have not filed a tax return.
Among the various new tax requirements 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. This is a must to file. The IRS will pursue non filers via the new tax software that is being updated in their system. IRS is building special groups within the Service to pursue Expats simply because of the large revenues that are brought in from Expats.
If all 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 will be subject to the IRC 877 and 877A expatriation tax provisions.
Call our Expat Lawyers, Attorneys and Former IRS agents to go over you case for no cost.
Individual taxpayers that have expatriated should file all tax returns that are due, regardless of whether or not full payment can be made with the return. It is most important to file even though you do not have the money. IRS cannot come after you criminally if you file.
Depending on a taxpayers individual’s circumstances, a taxpayer filing late may qualify for a payment plan. Many taxpayers may also qualify for a full abatement of penalties if reasonable cause exists. Expat Lawyers who are skilled in tax law can many times remove all penalties and interest. It is important you find qualified Expat Lawyers and Attorneys who have IRS tax experience.
Payment Plans
You can qualify for a payment plan if you cannot pay the tax in full. All payment plans require continued compliance with all filing and payment responsibilities after the plan is approved.
IRS to send notices to Expats
IRS is starting to send tax notices to expatriates that have not complied with the Form 8854 requirements, including the imposition of the $10,000 penalty where appropriate. The IRS collected over $4.4 billion dollars in the last 3 years and it will continue to work and develop tax systems to aggressively collect monies from Expats.
We can file all your back tax returns, get penalties and interest abated should you qualify and work out a tax settlement.
EXPAT LAWYER – Former IRS, Tax Lawyers – Expatriates Experts, International & Global Tax Firm – Free Consultations
by Fresh Start Tax | Jul 3, 2012 | FBAR, Representation, Tax Lawyer
Foreign Bank Account Reports – FBAR Lawyers, Former IRS – Free Tax Advice – FBAR Experts
FBAR is here to stay.IRS has found a pot of gold at the end of this FBAR rainbow.
The IRS and the U.S. Department of Treasury will make a living from FBAR alone. FBAR, Foreign Bank Account Reporting is paying the bills of the Treasury.
The Feds have collected over $4 Billion big ones so far and that they say is just the tip of the iceberg. Much more is coming, the more tax treaties the more money. When Lichtenstein falls it all goes.
The IRS is hiring more agents and gearing up their computer system CADE 2 to find tax cheats and tax evaders through their new computerized systems and it is working.
For years IRS has been getting by with 80’s technology and now with the new funding will catch up to modernization of modern day businesses and banks.
FBAR ( Foreign Bank Account Reports ) will not go away until the IRS sucks all the blood out of all the taxpayers who have the responsibility to file and report thru FBAR.
The Report of FinCEN, the definitive source for FBAR
Foreign Bank and Financial Accounts Report (FBAR) Responsibilities
“The Financial Crimes Enforcement Network (FinCEN) issued a rule that amends the Bank Secrecy Act (BSA) implementing regulations regarding the Report of Foreign Bank and Financial Accounts (FBAR).
The FBAR filing requirements, authorized under one of the original provisions of the BSA, have been in place since 1972.
The FBAR form is used to report a financial interest in, or signature or other authority over, one or more financial accounts in foreign countries. No report is required if the aggregate value of the accounts does not exceed $10,000.
On February 26, 2010, FinCEN issued a Notice of Proposed Rule making (NPRM) addressing the FBAR rules.
The final rule adopts the proposed changes with slight modifications.
The preamble to the new final rule explains FinCEN’s approach to issues raised in comments submitted in response to the NPRM from tax professionals and industry experts.
The preamble to the final rule: and I quote
explains whether an account is foreign and therefore reportable as a foreign financial account and addresses the treatment of custodial accounts in this context;
revises the definition of signature or other authority to more clearly apply to individuals who have the authority to control the disposition of assets in the account by direct communication (whether in writing or otherwise) to the foreign financial institution;
explains that an officer or employee who files an FBAR because of signature or other authority over the foreign financial account of their employer is not expected to personally maintain the records of the foreign financial accounts of their employer;
and also,
advises filers that they may rely on provisions of this final rule in order to determine their filing obligation for FBARs in those cases where filing was properly deferred under prior Treasury guidance.”
What the taxpayer should do re: (Foreign Bank Account Reports – FBAR)
Each taxpayer is responsible for their own reporting and financial disclosures to the IRS. At the present time IRS is giving grace to certain individuals where tax fraud is not involved. There will be a period of time in the near future in which the IRS will no longer forgive non-filers and delinquents.
Call us today for a no cost professional tax consultation. 1-866-700-1040
Speak directly to FBAR Tax Lawyers, Attorneys, and Former IRS Agents.
Foreign Bank Account Reports – FBAR Lawyers, Former IRS – Free Tax Advice – FBAR Experts
Areas of Professional Tax Practice:
- Same Day IRS Tax Representation
- FBAR Tax Representation
- Offers in Compromise or IRS Tax Debt Settlements
- Immediate Release of IRS Bank Levies or IRS Wage Garnishments
- Tax Relief from a IRS Bill, Letter or Notice of “Intent to Levy”
- IRS Tax Audits
- IRS Hardships Cases or Unable to Pay
- Payment Plans, Installment Agreements, Structured agreements
- Abatement of Penalties and Interest
- State Sales Tax Cases
- Payroll / Trust Fund Penalty Cases / 6672
- Filing Late, Back, Unfiled Tax Returns
- Tax Return Reconstruction if Tax Records are lost or destroyed
Our Company Resume: ( Since 1982 )
- Our staff has collectively over 205 years of Professional IRS Tax Representation Experience
- On staff, Board Certified Tax Attorney’s, IRS Tax Lawyers, Certified Public Accountants, Enrolled Agents,
- We taught Tax Law in the IRS Regional Training Center
- Former IRS Agents, Managers and Instructors with over 60 years experience in the local, district and regional IRS offices.
- Highest Rating by the Better Business Bureau “A”
- Fast, affordable, and economical
- Licensed and certified to practice in all 50 States
- Nationally Recognized Veteran /Published Former IRS Agent
- Nationally Recognized Published EZINE Tax Expert
- As heard on GRACE 90.3 FM Monthly Radio Show-Business Weekly
by Fresh Start Tax | Jun 28, 2012 | FBAR, IRS Tax Debt, Representation, Tax Lawyer, Tax Returns, Tax Settlements
FBAR – Tax Lawyers – File and Settle – IRS Tax & FBAR Experts
Take the fear out of FBAR.
We are a professional tax firm specializing in FBAR tax filings and tax negotiations. We are compromised of Board Certified Tax Lawyers, Tax Attorneys, CPA’s and Former IRS Agents who where both teaching instructors and former IRS managers when employed by the IRS. We have a combined 60 years who experience at the IRS.
We also taught Tax Law while employed by the IRS.
Our firm specializes in the filing, negotiation and tax debt settlements of World Wide FBAR cases.
The IRS viewpoint on FBAR
The Internal Revenue Service is starting ramp up enforcement of there International Tax Program and the latest goldmine for the feds is found in the FBAR filings and payment.
To date the IRS has found over $5 billion Dollars in collectables. With that type of money on the table the IRS is not going to quit. This makes the IRS look good!
As a matter of fact the IRS is dedicating much of there millions in enforcement budget specifically to this FBAR project.
After speaking to several IRS agents, the management of the IRS is going to “make FBAR headlines with there enforcement”. They want to scare taxpayers to death.
What hangs over the head of many of the taxpayers is the fear of going to jail and this is huge. It makes people jump and scares them into tax compliance. And, it has worked!
Who Must File an FBAR
United States persons are required to file an FBAR if:
The United States person had a financial interest in or signature authority over at least one financial account located outside of the United States; and
The aggregate value of all foreign financial accounts exceeded $10,000 at any time during the calendar year to be reported.
United States person means United States citizens; United States residents; entities, including but not limited to, corporations, partnerships, or limited liability companies created or organized in the United States or under the laws of the United States; and trusts or estates formed under the laws of the United States.
Exceptions to the Reporting Requirement
Exceptions to the FBAR reporting requirements can be found in the FBAR instructions.
There are filing exceptions for the following United States persons or foreign financial accounts:
1.Certain foreign financial accounts jointly owned by spouses;
2.United States persons included in a consolidated FBAR;
3.Correspondent/nostro accounts;
4.Foreign financial accounts owned by a governmental entity;
5. Foreign financial accounts owned by an international financial institution;
6.IRA owners and beneficiaries;
7.Participants in and beneficiaries of tax-qualified retirement plans;
8.Certain individuals with signature authority over but no financial interest in a foreign financial account;
9.Trust beneficiaries; and
10.Foreign financial accounts maintained on a United States military banking facility.
If you are looking to have true FBAR experts handle your case call us today for a no cost consult. 1-866-700-1040.
You will speak directly to a Tax Lawyer, Tax Attorney, CPA or a Former IRS Agents.
