866-700-1040

FBAR – Italy – File, Report, Settle, “Worry Free” – FBAR Tax Experts – Tax Attorneys, Lawyers, Former IRS – Expatriate Help

by | Oct 2, 2012 | Expatriate Tax, FBAR, Offshore Program, Offshore Tax Problems, Tax Lawyer

 

Make sure you file all FBAR reports because the IRS and the Department of Justice is putting in systems and getting cooperation for foreign banks and financial institutions to turn over the names of all account holders all over the world.

FBAR is coming your way because of the huge success that the Department of Justice and the IRS has had on the FBAR Program over the past 3 years.

IRS and the Department of Justice collected just north of $5 billion dollars as a result of the first couple of FBAR programs. Over 33,000 persons came forward and many many more are about to ante up to avoid jail time.

IRS and the DOJ hold the threat of prison time over the heads of non-filers and non reporters and the best advice we can give you is to” find the IRS before they find you.”

With the break through of UBS and Liechtenstein, the IRS and the DOJ is working there way country by country.

Why to use Fresh Start Tax LLC.

We are comprised of Board Certified Tax Attorneys, Tax Lawyers, CPA’s and Former IRS agents. We have over 205 years pf professional tax experience and over 60 years of working directly for the IRS in the local, district and regional offices.

We taught Tax Law and know all the tax procedures, thinking and settlement objectives of the IRS. We have a world wide tax practice.

News from Liechtenstein that will effect other countries including Italy and the surrounding areas.

You should known that Liechtenstein was never thought to give away to US pressure. It was such a small country. A little Alpine ski resort of 36,000 persons, it was a tax free haven for years for persons wanting to hide their money free of government reprisal. It was one of the greatest of all tax havens. For many tax professionals involved it was the country of choice because it was called the Teflon Tax country.

The US came in hard and the with the pressure Liechtenstein gave way.

Liechtenstein finally informed on their Bank Clients on the U.S. Tax Evasion Request

Liechtenstein has told all their American clients of the principality’s oldest bank that U.S. authorities have requested their account data as they widen a tax evasion and potential tax fraud probe.

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.

Who is required to file 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).

The FBAR is required because foreign financial institutions may not be subject to the same reporting requirements as domestic financial institutions.

The FBAR is a tool to help the United States government identify persons who may be using foreign financial accounts to circumvent United States law. Investigators use FBARs to help identify or trace funds used for illicit purposes or to identify unreported income maintained or generated abroad.

 International Interests:

Individuals or Businesses with International Interests, if you need help or assistance in the following areas call us today: 1-866-700-1040

1. Reporting required for foreign corporations, partnerships, and trusts,
2. Tax Treatment of Passive Foreign Investment Companies,
3.  Foreign Bank Account Reporting and consultations,
4. Donations to foreign charities by United States private foundations,
5. Determination for residency for income tax purposes for Foreign Nationals,
6.  A Application of Tax Treaties and Totalization Agreements to minimize United States Tax,
7. State residency and Domicile issues,
8. Analysis of foreign tax credit(s) versus foreign earned income exclusions for US expatriates.

 

The triggering mechanism – The United States Bank Secrecy Act

The US Congress passed the Bank Secrecy Act in 1970 as the first laws to fight money laundering in the United States. The BSA requires businesses to keep records and file reports that are determined to have a high degree of usefulness in criminal, tax, and regulatory matters.

 

The documents filed by businesses under the BSA requirements are heavily used by law enforcement agencies, both domestic and international to identify, detect and deter money laundering whether it is in furtherance of a criminal enterprise, terrorism, tax evasion or other unlawful activity.

 

The Internal Revenue Service is a partner in the U.S. National Money Laundering Strategy. The IRS seeks to achieve a balance between enforcement of the money laundering laws and education. This page provides links to information about specific BSA requirements to assist with education and compliance with the law.

FBAR Help – Italy – Report, File, Settle – Tax Lawyers Attorneys, Former IRS – FBAR, Expat Experts

by | 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.