by Fresh Start Tax | Jul 4, 2012 | Back Taxes, FBAR, IRS Tax Problem, Representation, Tax Lawyer, Tax Returns
FBAR Filings – Free Tax Advice – Tax Attorneys, Lawyers – Former IRS
There are many questions regarding the filing of FBAR and making Voluntary Disclosures to the IRS.
There are also various opinions on how this should be done.
It is always best to speak directly to a tax attorney, tax lawyer or Former IRS Agent to go over all your tax options regarding FBAR and Voluntary Disclosure.
We are a professional tax firm specializing in FBAR and ExPat cases.
These are two of the most common questions asked:
1. 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 these 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.
The IRS along with different countries are putting in tax treaties to deal with the problem of unreported FBAR based on bank account information they are currently receiving.
Due to recent funding the IRS is ramping up CADE 2, the new IRS computer system that will help full compliance.
It is in the best interest to all taxpayers to find the IRS before they find you.
2. 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.
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 not recommend criminal prosecution to the Department of Justice.
The general rule of thumb, file first and beat criminal prosecution.
FBAR & Voluntary Disclosure – IRS FBAR Tax Relief – Tax Experts – Tax Attorneys, CPA’s, Former IRS
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- 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,
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by Fresh Start Tax | Jul 3, 2012 | FBAR, Tax Lawyer
Needless to say the reason you have looked us up is because the Internal Revenue Service is spending a lot and time and money to get FBAR under control. This is something you may be worried about or just have questions.
As former IRS Agent I can tell you from work experience, the IRS was sealed out of Foreign Bank accounts until the UBS debacle. Since UBS the IRS is on steroids going after taxpayers who are hiding money offshore. If this is you, tax representation is a must.
It is important to know that each case is uniquely different. Some of the factors the IRS reviews are:
1. Size of the case,
2. The history of the taxpayer,
3. Money involved,
4. Chance of a successful audit, collection or prosecution,
5. Badges of Fraud.
As a Former IRS Agent we looked at all these factors before spending loads of time on each case. It was just not prudent to after everyone.
With that said, your case is unique and needs to be looked at in the eyes of the IRS and it is important to understand their determining criteria.
At Fresh Start Tax L.L.C. we are a professional tax firm comprised of Board Certified Tax Attorneys, Lawyers, CPA’s and Former IRS Agents and Instructors.
When employed at the IRS I taught Tax Law.
If you have questions about FBAR and tax representation call us for a no cost professional consult. 1-866-700-1040
All your information is confidential and you will be afforded attorney – client privileged.
We have over 205 years of professional tax experience and over 60 years of direct work experience at the IRS.
Our Tax Attorneys and Tax Lawyers can help and work through this situation.
Call today and speak directly to a Lawyer/Attorney. 1-866-700-1040
FBAR – Lawyers/Attorneys – Former IRS, Tax Experts – Affordable
by Fresh Start Tax | Jun 27, 2012 | Abatements, Back Taxes, Expatriate Tax, FBAR, Income Tax Preparation, IRS Tax Problem, Representation, Tax Lawyer, Tax Returns, Tax Settlements
The IRS is already starting to bear down very hard on Ex-Pats and there late, past due and or delinquent tax returns.
The IRS has dedicated so much more revenue to oversees tax collections and tax audits. These groups of agents are called Revenue Agents. They are currently being trained to go after easy tax money and easy tax targets, and those are the Expats. they have been well trained and also experienced for fraud indications.
The IRS has finally wised up and realized that instead of going after the deadbeats who lives within the boundaries or confines of this great country, the new found jackpot is where the money and the leverage is sitting and that my friends is the IRS new target, Ex Pats and FBAR.
Many of the Ex-Pats who have not filed were unaware of the filing issue or the tax laws. I would say over 50% of the cases we work are due to the lack of knowledge and ignorance of the law. If that is the case, we can get penalties and interest, removed or abated for reasonable cause.
How we handle Ex Pat cases regarding late, past due, back or delinquent returns:
We send to IRS a Power of Attorney indicating that the IRS is not to talk or contact the taxpayer.
We then secure the necessary documentation from our client and secure internal records that the IRS has in house. IRS stores all income information for 7 years.
In the case of lost records we file reconstructed tax returns. We have filed so many reconstructed tax returns these never become a problem. A good deal of taxpayers who have lost there records are afraid to file because many years have gone by. Believe it or not IRS is happy to get the returns and get you back in tax compliance.
Keep one thing in mind, if the IRS sends you a letter about filing your late, back, past due or delinquent tax returns and you do not respond,the IRS has the right to file for you and this a called a substitute for return. ( SRF )
The bottom line, we can file all your tax returns with or without records and also settle your back IRS tax debt.
We are comprised of Tax Attorneys, CPA’s and Former IRS agents with over 60 years of professional tax experience.
Call us today for a no cost consult. 1-866-700-1040
Call us and see how easy this can be. You can do this worry free!
by Fresh Start Tax | Jun 25, 2012 | Expatriate Tax, FBAR, Representation, Tax Lawyer
FBAR – Offshore Voluntary Disclosure – Tax Attorneys, IRS Tax Experts – Former IRS – Tax Representation
Have IRS Tax Experts in FBAR in the Offshore Voluntary Disclosure Program (OVDP) represent you before the Internal Revenue. Why call any other tax firm when we worked for the IRS and know there tax policies and procedures.
Our team is comprised of Board Certified Tax Attorneys, CPA’s and Former IRS agents, managers and teaching instructors with the IRS.
We have over 205 years of professional tax experience and over 60 years working directly with the IRS.
As you may know the Internal Revenue Service ( IRS ) reopened the Offshore Voluntary Disclosure Program to help people hiding offshore accounts get current with their taxes and announced the collection of more than $4.4 billion so far from the two previous international programs.
The third offshore program.
The Third and new 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 3rd program will be open for an indefinite period until otherwise announced. The IRS has collected far more money than expected and this program will continue to generate large dollars of revenue into the federal government.
The new OVD program is similar to the 2011 program in many ways, but with a few key differences.
There is no set deadline for people to apply.
However, the terms of the program could change at any time going forward. For example, the IRS may increase penalties in the program for all or some taxpayers or defined classes of taxpayers – or decide to end the program entirely at any point.
The third offshore effort comes as Shulman also announced today 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. We are expecting those numbers to soar.
Since the 2011 program closed last September, hundreds of taxpayers have come forward to make voluntary disclosures.
Those who have come in since the 2011 program closed last year will be able to be treated under the provisions of the new OVDP program.
The overall penalty structure for the new program is the same for 2011, except for taxpayers in the highest penalty category. It is best to look into the abate of certain penalties as it relates to FBAR.
Penalty Structure
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. 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.
Call us today for a no cost professional consult and speak direct to a tax attorney who is a true IRS tax expert.
We specialize in all areas of Ex- Pats Tax Representation.
by Fresh Start Tax | Jun 18, 2012 | Back Taxes, Income Tax Preparation, Installment Agreements, IRS Tax Problem, Offer in Compromise, Representation, Tax Help, Tax Lawyer, Tax Returns
If you are a Ex Pat and you need to file your late, back, past due or unfiled tax returns call us today for a free tax consult and get rid of the worry you are dealing with.
We handle all contact with the IRS and you will never speak to them. We fully prepare all back income tax returns and work out a tax settlement if necessary.
Being comprised of Board Certified Tax Attorneys, CPA’s and Former IRS agents we have over 205 years of professional tax experience and over 60 years of working directly for the IRS in the local, district and regional offices of the IRS.
We can not only file all of your back returns we can settle all back tax debt should you owe money to the IRS.
What to do if you have not filed an Income Tax Return:
Among the various new requirements contained in IRC 877 and 877A, individuals that renounced their US 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 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.
Individuals 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 require continued compliance with all filing and payment responsibilities after the plan is approved.
We handle and settle all FBAR cases with true experienced tax professional.
Call today and speak directly to a Tax Attorney. 1-866-700-1040
