FBAR/OVDI LANCE WALLACH FBAR Foreign Bank Account Reporting The IRS is assessing huge penalties for undisclosed foreign bank accounts, assets & income. Click for more info FBAR FILING DEADLING HAS BEEN EXTENDED
Tuesday, August 20, 2013 FBAR & INT'L Tax Report! Need Help With Your Foreign Bank Account?
Click Link Below Free FBAR & INT'L Tax Alert report
http://lawyer4audits.com/fbar-ovdi-international.html Posted by Lance Wallach at 12:57 PM Email This BlogThis! Share to Twitter Share to Facebook Share to Pinterest
Labels: FBAR, international tax, Lance Wallach, Opt-Out, OVDI 1 comment:
lance wallachMarch 12, 2014 at 3:25 PM FBAR/OVDI LANCE WALLACH FBAR Foreign Bank Account Reporting The IRS is assessing huge penalties for undisclosed foreign bank accounts, assets & income. Click for more info FBAR FILING DEADLING HAS BEEN EXTENDED
Tuesday, December 24, 2013 FBAR Offshore Bank Accounts and Foreign Income Attacked by IRS FBAR Offshore Bank Accounts and Foreign Income Attacked by IRS Posted by Lance Wallach at 9:19 AM 1 comment: Email This BlogThis! Share to Twitter Share to Facebook Share to Pinterest
As an expert witness, Lance Wallach has never lost a case. Lance Wallach has also written "CPA's guide to life insurance". http://lancewallachchfc.blogspot.com/ https://www.youtube.com/watch?v=WTMWg6bn0Bc http://multinationaltaxesfbarovdi.blogspot.com/2013/12/fbar-international-tax-alert-report.html?showComment=1397481749542#c7747324770018422953 click the links for more information
Reporting by U.S. Persons Holding Foreign Financi Contact Information Email : Lanwalla@aol.com Phone : 516-983-5007 Address : Lance Wallach www.TaxAudit419.com www.Vebaplan.org IRS Form 8938 FATCA requires any U.S. person holding foreign financial assets with an aggregate value exceeding $50,000 to report certain information about those assets on a new form (Form 8938) that must be attached to the taxpayer’s annual tax return. Reporting applies for assets held in taxable years beginning on or after January 1, 2011. Failure to report foreign financial assets on Form 8938 will result in a penalty of $10,000 (and a penalty up to $50,000 for continued failure after IRS notification). Further, underpayments of tax attributable to non-disclosed foreign financial assets will be subject to an additional substantial understatement penalty of 40 percent. Under FATCA, U.S. taxpayers holding financial assets outside the United States must report those assets to the IRS on a new form attached to their tax return. Penalties apply for failure to comply with this new reporting requirement. Reporting is required for assets held in taxable years beginning on or after January 1
Lance Wallach More Credentials: National Society of Accountants Speaker of the Year and member of the AICPA faculty of teaching professionals Frequent speaker on retirement plans, financial and estate planning, and abusive tax shelters. Writes about 412(i), 419, and captive insurance plans. Speaks at more than ten conventions annually Writes for more than fifty publications Is quoted regularly in the press and has been featured on television and radio financial talk shows including NBC, National Pubic Radio's All Things Considered, and others. Author of Protecting Clients from Fraud, Incompetence and Scams published by John Wiley and Sons Author of Bisk Education's CPA's Guide to Life Insurance and Federal Estate and Gift Taxation. Author of AICPA best-selling books, including Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots. Lance Wallach publishes extensively on this subject - something the authorities look for in an Expert Witness:
Get Sued!
Small Business and Retirement Plans Fuel Litigation
Advisors Staring at a New "Slew" of Litigation from Small Business Clients
IRS Says Most 419 Plans are Abusive Tax Shelters Call 516 - 938 - 5007 TODAY!
What Plan Were You In? When you have "IRS problems", you need a proven winner to stand up to them and help you avoid "IRS penalties and fines.
If you are suffering from "IRS tax penalties you should know that when Lance Wallach was on a team.........
His side never lost a case!
Due to recent changes in "IRS regulations", both participants and their "material advisors" can be subject to large "IRS tax penalties"! The IRS is auditing many of these "benefit plans" right 516 - 938 - 5007 for preventive advice today before it's too late! Nationwide Assistance! For Nationwide Assistance Email Here Expert Witness Services
Litigation Consulting Case Evaluation Evidence Review and Forensic Analysis Research Complaint, Petition, and Response Preparation Assistance Damage Calculations Expert Declarations and Affidavits Exhibits for Settlement Conference, Mediation, and Trial Active Litigation: Rebuttal W
compensation: no pay Lance Wallach helps with 419 problems. 412i 419 abusive tax shelters IRS audits, lawsuits, Lance Wallach will help www.vebaplan.com 419, 412i, IRS audits, Lance Wallach, Google him helps, The following had something to do with this. Dennis Cunning Steve Toth Randall Smith Paul Kaplan Herb Green Casey Hermansen Larry Bell Scott Ridge Judy Carsrud Jeffrey Glasberg Herb McDowel Greg Roper Joseph Donnelly Norm Bevan Michael Sonnenberg Dan Carpenter Anthony Fakouri Steve Burgess Robin Weingast IRS audits 419 412i captive insurance and section 79 plans. Lance Wallach will help you.
IRS audits section 79 419 412i plans. www.lancewallach.com for help Benistar, IRS raids, Niche, Robin Weingast, Lance Wallach helps, Sadi trust, grist Mill trust, nova 419 welfare benefit plan problems and how Lance Wallach helps.www.vebaplan.com for more help. Sea Nine VEBA, 419, 412i, IRS audits,Sea Nine VEBA, Benistar, Grist Mill Trust are all audited by the IRS and people in them probably need help. Sea Nine VEBA, 419,412i are all IRS audit targets. Lance Wallach can help, www.tazaudit419.com 419, 412i, IRS audits, Lance Wallach, Google him helps, The following had something to do with this. Author to write about these problems. Dennis Cunning Steve Toth Randall Smith Paul Kaplan Herb Green Casey Hermansen Larry Bell Scott Ridge Judy Carsrud Jeffrey Glasberg Herb McDowel Greg Roper Joseph Donnelly Norm Bevan Michael Sonnenberg Dan Carpenter Anthony Fakouri Steve Burgess Robin Weingast "SADI Trust" Lance Wallach will help fix the problems that people have that are or were in the plans. "Professional Benefits Trust" PBI
"Sea Nine Veba" Bisys The "Beta Plan" The "Millennium Plan" Benistar Niche The "Ridge Plan"
The "Grist Mill Trust" The "Compass Welfare Benefit Plan" "Section 79 Plans" "Captive Insurance" and other similar "412i retirement plans" and "419 welfare benefit plans
Lance Wallach, www.taxaudit419.com will help you with these problems and more like section 79, captive insurance lawsuits and IRS audits. People in the section 79 plans 419 welfare benefit plans captive insurance and 412i pension plans are getting audited by the IRS and then they sue. Google Lance Wallach for help with this. If you need help Lance Wallach as an expert witness has never lost a case. You need help NOW.
Customers of James Cunningham d/b/a Cunningham Financial or CFG Consulting LLC? We want to speak with you! IRS audits and lawsuits result from 419 412i captive insurance and section 79 plans. As an expert witness Lance Wallach has never lost a case.
Lance Wallach | blinkbox books https://www.blinkboxbooks.com/#!/author/.../lance-wallach We're not usually lost for words, but on this occasion we have to confess that we don't have all the author's details at the moment. We hope to have more details ... FBAR/OVDI LANCE WALLACH: FBAR-What are You Hiding
beat-the-irs.blogspot.com/.../fbarovdi-lance-wallach-fbar-what-a... by Lance Wallach - in 57 Google+ circles Mar 18, 2014 - 412i-419 Plans. 419 & 412i benefit plan,abusive tax shelters, Lance Wallach Expert Witness ... spots by the AICPA, author/moderator. Lance ... You +1'd this
Blog Post Subscribe Recent Posts Lance Wallach Wrote the Book Tuesday, April 08, 2014 What are My Self-Employed Tax Obligations? Tuesday, February 25, 2014 For Your Information_Call For Assistance Monday, January 06, 2014 Fatca, Fbar, Offshore Amnesty Large Fines Coming Monday, November 18, 2013 Currently Non Collectible (CNC) status Wednesday, October 30, 2013 Captive Insurance Tuesday, September 17, 2013 Operator of Tax Preparation Business Sentenced to 17 ½ Years in Prison in Fraudulent Tax Shelter Conspiracy Tuesday, August 06, 2013 Manage your IRS debts with ease – 4 Simple steps at your disposal Monday, July 01, 2013 NOTICE TO INTERESTED PARTIES Thursday, May 30, 2013 Have you invested in a 419, 412i or Section 79 pension plan? Tuesday, March 26, 2013 Bio Link Twitter Link LanceWallach Follow me on Twitter Twitter RSS Lance Wallach Wrote the Book
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Author/Moderator: Lance Wallach, CLU, CHFC, CIMC Publisher: AICPA Availability: In Stock Chapter 1 - Planning for Business Owners Learning Objectives Introduction Building the Perfect Retirement Plan SEP IRA: The Good SEP IRA: The Bad SEP IRA: The Ugly The K The Double K Defined Benefit Plans Adding Survivor Benefits 412(i) Defined Benefit Plan Cash Balance Plans VEBAs and 419 Plans Taxability of Trust Net Income Taxability of Excess Benefits Group-Term Life Insurance Plan Post-Retirement Medical Benefit Voluntary Employees Beneficiary Association (VEBA) - Commentary New Development - Welfare Benefit Plans under Section 419(e) Executive Carve Out Long-Term Care What Is Long-Term Care? How Much Does It Cost Benefits of Long-Term Care Insurance to Employees Benefits of Long-Term Care Insurance to Employers Executive Carve Out Long-Term Care Taxability Long-Term Care Insurance Premium Deductibility 2007 Eligible Long-Term Care Insurance Premiums Age-Based Deduction Limits
Material Advisors & 419 Plans Litigation 412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.
Tuesday, February 28, 2012 Lance Wallach National Society of Accountants Speaker of The Year
Posted by Lance Wallach at 10:58 AM Email This BlogThis! Share to Twitter Share to Facebook Share to Pinterest
412i IRS audits, listed transactions ________________________________________ April 24, 2012 By Lance Wallach, CLU, CHFC ________________________________________
IRS auditing 412i plans Protecting Clients From Fraud, Incompetence, and Scams By: Lance Wallach Published by John Wiley and Sons, Inc. Copyright Ó 2010. All rights reserved.
Wednesday, March 12, 2014 FBAR/OVDI LANCE WALLACH: FBAR Offshore Bank Accounts and Foreign Income Att... FBAR/OVDI LANCE WALLACH: FBAR Offshore Bank Accounts and Foreign Income Att...: FBAR Offshore Bank Accounts and Foreign Income Attacked by IRS
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Captive Insurance & 419 Plans Litigation lancewallachchfc.blogspot.com/ Feb 27, 2014 - By Lance Wallach, Consultant & Expert Witness. Recent court cases have highlighted serious problems in welfare benefit plans issued by Nova
FBAR/OVDI LANCE WALLACH FBAR Foreign Bank Account Reporting The IRS is assessing huge penalties for undisclosed foreign bank accounts, assets & income. Click for more info FBAR FILING DEADLING HAS BEEN EXTENDED
Thursday, December 5, 2013 FBAR & International Tax Alert Report
The willful failure to file the FBAR report or retain records of your foreign accounts can potentially lead to a ten-year prison sentence and fines of up to $500,000. This criminal penalty applies to all US citizens pursuant to 31U.S.C Section S322B and 31 C.F.R. Section 103.S.9.C It may also apply to persons living in the United States who are not citizens. If you fail to answer the question truthfully on schedule B of your Form 1040 which asks if you “have an interest in or a signature or other authority over a financial account in a foreign country”, then your false statement might be deemed a criminal offense by the IRS per the sections mentioned above if other surrounding facts and circumstances apply.
Our office is headed by a former international tax IRS agent with 37 years experience as a CPA and Associate Professor of accounting. Call our office immediately for a free five-minute consultation so you can avoid the dire circumstances described above and deal with the other associated problems.
FBAR/OVDI LANCE WALLACH FBAR Foreign Bank Account Reporting The IRS is assessing huge penalties for undisclosed foreign bank accounts, assets & income. Click for more info FBAR FILING DEADLING HAS BEEN EXTENDED
First, since 2009 there have been three (3) formal opportunities for U.S. taxpayers to come forward. There was the 2009, 2011, 2012 and now the 2013 programs.
Second, offshore banks have been sending out letters to U.S. based account holders requesting that they attest to compliance with FBAR reporting and closing some accounts for non-compliance. The due diligence provisions Foreign Account Tax Compliance Act (FATCA) are now in effect and offshore banks with U.S. correspondent banking agreements are scouring their records for U.S. account holders. These banks are requesting consent from U.S. account holders to disclose information about the U.S. account holder to the IRS.
Third, The Justice Department has brought actions against several offshore banks, Switzerland, Luxembourg, and Israel to compel disclosure of information about U.S. account holders.
Finally, beginning with 2011, Form 1040 has specific questions on Schedule B about whether the taxpayer filed an FBAR. Yet, in spite of all of the information many U.S. taxpayers, including those who are resident aliens have refused to come forward. Some of the reasons for not coming forward are fear based, and some based upon risk/reward estimates. In each case the outcome if caught is so terrible, that it is hard to imagine why anyone would refuse to come forward. However, in the following situations it is overwhelmingly likely that you will caught – and as in most things of this nature, the consequences will largely be determined by who gets to whom first:
Example 1: Taxpayers are resident aliens who claim to have inherited funds in excess of $100,000 somewhat recently. The funds were kept in an offshore account and not reported for either income tax or FBAR purposes. Here are the potential results. First, a Report of Foreign Gift or Bequest was due for income tax purposes. While no estate or gift tax was due the failure to file Form 3520 when due can result in a civil penalty of between 25% -35% of the amount of the bequest, (for simply not filing). If the taxpayers filed an FBAR and Form 3520 timely there would be no penalties at all and no tax due Second, the taxpayer's now face a civil FBAR penalty of the greater of 50% or $100,000 of the highest account balance per year. If, however, they enter the offshore voluntary disclosure program the maximum combined civil penalty is 27.5% of the highest single year account balance. While the civil penalty is costly, the "ostrich" approach is likely to be catastrophic.
FBAR/OVDI LANCE WALLACH FBAR Foreign Bank Account Reporting The IRS is assessing huge penalties for undisclosed foreign bank accounts, assets & income. Click for more info FBAR FILING DEADLING HAS BEEN EXTENDED
Thursday, June 20, 2013 Foreign Bank Account Report, Treasury Department Form 90-22.1 (FBAR)
Who Must File an FBAR: Generally, every U.S. person with a financial interest in or signature or other authority over, any financial account outside of the United States, must file an FBAR if the aggregate value of all accounts exceeds $10,000 at any time during the calendar year. An FBAR must be filed by U.S. taxpayers that have signature authority over any account, even if they have no financial interest in or are not the owner of the account. Such accounts include but are not limited to: bank, securities, pension funds, other financial accounts, any accounts with commingled funds, any accounts held by entities for which the individual is a shareholder/owner, etc.
FBAR Filing Deadline: The FBAR must be received on or before June 30th of the year following the calendar year being reported. It is not filed with your federal tax return. June 30, 2012 falls on a Saturday this year, but there has been no official announcement that individuals will not face late filing penalties if the FBAR is not received by the deadline. Therefore it may be prudent to file so that it is received by June 29, 2012. There are three (3) pages of instructions and information as to the specific form and instructions can be found on irs.gov and/or bsaefiling.fincen.treas.gov. It should be noted that the information provided on these sites (as well as this site) should not be construed as legal advice.
How FBAR information can be used: The information collected by the reporting can be provided to officers and employees of any division of the Treasury Department. These records may be utilized in performance of their duties and investigations as well as referred to other federal, state or local authority upon request for use in criminal, tax, regulatory investigation or proceeding, or other investigations and matters.
Do you need an attorney for FBAR issues? If you have never filed an FBAR but should have --> you should immediately consult with a tax attorney familiar with international tax law or with a CPA that was with the IRS division of international tax. If you are concerned about how the information will be used or could be used against you --> you should immediately consult with a tax attorney familiar with international tax law and financial/white collar crime defense or with an ex IRS official who is a CPA.
If you filed an incomplete or false FBAR --> you should immediately consult with a tax attorney who is familiar with international tax law and financial/white collar crime defense or with a CPA that was with the international division of the IRS.
How to get your tax law questions answered - confidentially: You may wish to consult with an experienced tax attorney or with an ex IRS agent before filing the FBAR form or any other financial document that is requested or required of you because a seemingly simple form (admittedly, financial forms are never "that" simple) have far reaching consequences that can come back to haunt you
FBAR Offshore Bank Accounts and Foreign Income Attacked by IRS
Aug 10, 20110149
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Lance Wallach
RELATED ARTICLES IRS May Offer New Amnesty For Offshore Tax Evaders New Charges Against UBS Banker - Business as Usual for the Swiss? Voluntary Disclosure Program - U.S. Taxpayers Can Still File Taxman eyes up Virgin Islands and Panama
You may want to think about participation in the IRS' offshore tax amnesty program (called the Offshore Voluntary Disclosure Initiative). Do you want to play audit roulette with the IRS? Some clients think they are too small to be prosecuted. They are wrong.
To the average businessperson, only the guys with tens of millions secretly stashed in Swiss bank accounts get prosecuted. Don't tell that to Michael Schiavo. He was just prosecuted for hiding money in a Swiss account back in 2003. How much money does the IRS say he hid? A whopping $90,000. That's it.
But wait, there is more to the story. Schiavo attempted to do a quiet disclosure during the 2009 amnesty but instead of filling out the amnesty paperwork, he simply trusted that by coming forward voluntarily he could avoid criminal prosecution. He was wrong on all counts. Nothing is too small for the IRS, and nothing is too old.
"So, to save a whopping $40,624 in taxes, this guy risked a felony conviction and prison time, not to mention steep penalties that could very easily eat up the entire $90,000, and also his criminal and civil defense costs.
The smart taxpayers are the ones coming forward and not having to look over their shoulders for the next 10 years.
Time is running out. The tax amnesty runs through August but it takes at least days to jump through all the hoops. We will also fight hard to reduce the penalties down even more. Remember, the IRS can go as low as 5%. Don't want this to happen to you? Visit taxadvisorexpert.com today!
Lance Wallach, National Society of Accountants Speaker of the Year and member of the AICPA faculty of teaching professionals, is a frequent speaker on retirement plans, financial and estate planning, and abusive tax shelters. He writes about 412(i), 419, and captive insurance plans. He speaks at more than ten conventions annually, writes for over fifty publications, is quoted regularly in the press and has been featured on television and radio financial talk shows including NBC, National Pubic Radio's All Things Considered, and others. Lance has written numerous books including Protecting Clients from Fraud, Incompetence and Scams published by John Wiley and Sons, Bisk Education's CPA's Guide to Life Insurance and Federal Estate and Gift Taxation, as well as AICPA best-selling books, including Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots. He does expert witness testimony and has never lost a case. Contact him at 516.938.5007, wallachinc@gmail.com or visit www.taxaudit419.com.
. Reporting by U.S. Persons Holding Foreign Financi Contact Information Email : Lanwalla@aol.com Phone : 516-983-5007 Address : Lance Wallach www.TaxAudit419.com www.Vebaplan.org IRS Form 8938 FATCA requires any U.S. person holding foreign financial assets with an aggregate value exceeding $50,000 to report certain information about those assets on a new form (Form 8938) that must be attached to the taxpayer’s annual tax return. Reporting applies for assets held in taxable years beginning on or after January 1, 2011. Failure to report foreign financial assets on Form 8938 will result in a penalty of $10,000 (and a penalty up to $50,000 for continued failure after IRS notification). Further, underpayments of tax attributable to non-disclosed foreign financial assets will be subject to an additional substantial understatement penalty of 40 percent. Under FATCA, U.S. taxpayers holding financial assets outside the United States must report those assets to the IRS on a new form attached to their tax return. Penalties apply for failure to comply with this new reporting requirement. Reporting is required for assets held in taxable years beginning on or after January 1
Why is it so dangerous to get it wrong? The FBAR form is a informational return that any US taxpayer who owns or controls foreign financial accounts that exceed $10,000.00 in total must file with the IRS every June, regardless if an extension to file a 1040 was filed or not. The FBAR is not sent in with form 1040, but rather, to an address in Detroit. The complications and strange rules of the FBAR are best explained by explaining the evolution of the form, and law and regulations that changed along the way.
FBAR Offshore Bank Accounts and Foreign Income Attacked by IRS
Aug 10, 20110149
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Lance Wallach
RELATED ARTICLES IRS May Offer New Amnesty For Offshore Tax Evaders New Charges Against UBS Banker - Business as Usual for the Swiss? Voluntary Disclosure Program - U.S. Taxpayers Can Still File Taxman eyes up Virgin Islands and Panama
You may want to think about participation in the IRS' offshore tax amnesty program (called the Offshore Voluntary Disclosure Initiative). Do you want to play audit roulette with the IRS? Some clients think they are too small to be prosecuted. They are wrong.
To the average businessperson, only the guys with tens of millions secretly stashed in Swiss bank accounts get prosecuted. Don't tell that to Michael Schiavo. He was just prosecuted for hiding money in a Swiss account back in 2003. How much money does the IRS say he hid? A whopping $90,000. That's it.
But wait, there is more to the story. Schiavo attempted to do a quiet disclosure during the 2009 amnesty but instead of filling out the amnesty paperwork, he simply trusted that by coming forward voluntarily he could avoid criminal prosecution. He was wrong on all counts. Nothing is too small for the IRS, and nothing is too old.
"So, to save a whopping $40,624 in taxes, this guy risked a felony conviction and prison time, not to mention steep penalties that could very easily eat up the entire $90,000, and also his criminal and civil defense costs.
The smart taxpayers are the ones coming forward and not having to look over their shoulders for the next 10 years.
Time is running out. The tax amnesty runs through August but it takes at least days to jump through all the hoops. We will also fight hard to reduce the penalties down even more. Remember, the IRS can go as low as 5%. Don't want this to happen to you? Visit taxadvisorexpert.com today!
Lance Wallach, National Society of Accountants Speaker of the Year and member of the AICPA faculty of teaching professionals, is a frequent speaker on retirement plans, financial and estate planning, and abusive tax shelters. He writes about 412(i), 419, and captive insurance plans. He speaks at more than ten conventions annually, writes for over fifty publications, is quoted regularly in the press and has been featured on television and radio financial talk shows including NBC, National Pubic Radio's All Things Considered, and others. Lance has written numerous books including Protecting Clients from Fraud, Incompetence and Scams published by John Wiley and Sons, Bisk Education's CPA's Guide to Life Insurance and Federal Estate and Gift Taxation, as well as AICPA best-selling books, including Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots. He does expert witness testimony and has never lost a case. Contact him at 516.938.5007, wallachinc@gmail.com or visit www.taxaudit419.com.
The information provided herein is not intended as legal, accounting, financial or any type of advice for any specific individual or other entity. You should contact an appropriate professional for any such advice
FBAR_OVDI & 419 Plans Litigation FBAR,OVDI,OPT-OUT,AMNESTY412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.
Tuesday, September 4, 2012 IRS: Disclose Offshore Accounts or Go to Jail
IRS: Disclose Offshore Accounts or Go to Jail Brian
That's pretty much the headline from a CNBC article on Friday. And it's true.
In 2009, 15,000 Americans came forward and admitted having foreign bank accounts. Unfortunately, Uncle Sam estimates there are some 500,000 more people hiding money offshore. Opening a bank account in another country isn't illegal. There are a whole host of reasons why people may wish to send money offshore. It only becomes illegal when you send money to a foreign country in the hopes of cheating Uncle Sam. Reply
FBAR Offshore Bank Accounts and Foreign Income Attacked by IRS
Aug 10, 20110149
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Lance Wallach
RELATED ARTICLES IRS May Offer New Amnesty For Offshore Tax Evaders New Charges Against UBS Banker - Business as Usual for the Swiss? Voluntary Disclosure Program - U.S. Taxpayers Can Still File Taxman eyes up Virgin Islands and Panama
You may want to think about participation in the IRS' offshore tax amnesty program (called the Offshore Voluntary Disclosure Initiative). Do you want to play audit roulette with the IRS? Some clients think they are too small to be prosecuted. They are wrong.
To the average businessperson, only the guys with tens of millions secretly stashed in Swiss bank accounts get prosecuted. Don't tell that to Michael Schiavo. He was just prosecuted for hiding money in a Swiss account back in 2003. How much money does the IRS say he hid? A whopping $90,000. That's it.
But wait, there is more to the story. Schiavo attempted to do a quiet disclosure during the 2009 amnesty but instead of filling out the amnesty paperwork, he simply trusted that by coming forward voluntarily he could avoid criminal prosecution. He was wrong on all counts. Nothing is too small for the IRS, and nothing is too old.
"So, to save a whopping $40,624 in taxes, this guy risked a felony conviction and prison time, not to mention steep penalties that could very easily eat up the entire $90,000, and also his criminal and civil defense costs.
The smart taxpayers are the ones coming forward and not having to look over their shoulders for the next 10 years.
Time is running out. The tax amnesty runs through August but it takes at least days to jump through all the hoops. We will also fight hard to reduce the penalties down even more. Remember, the IRS can go as low as 5%. Don't want this to happen to you? Visit taxadvisorexpert.com today!
Lance Wallach, National Society of Accountants Speaker of the Year and member of the AICPA faculty of teaching professionals, is a frequent speaker on retirement plans, financial and estate planning, and abusive tax shelters. He writes about 412(i), 419, and captive insurance plans. He speaks at more than ten conventions annually, writes for over fifty publications, is quoted regularly in the press and has been featured on television and radio financial talk shows including NBC, National Pubic Radio's All Things Considered, and others. Lance has written numerous books including Protecting Clients from Fraud, Incompetence and Scams published by John Wiley and Sons, Bisk Education's CPA's Guide to Life Insurance and Federal Estate and Gift Taxation, as well as AICPA best-selling books, including Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots. He does expert witness testimony and has never lost a case. Contact him at 516.938.5007, wallachinc@gmail.com or visit www.taxaudit419.com.
The information provided herein is not intended as legal, accounting, financial or any type of advice for any specific individual or other entity. You should contact an appropriate professional for any such advice
FBAR Offshore Bank Accounts and Foreign Income Attacked by IRS
Aug 10, 20110149
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Lance Wallach
RELATED ARTICLES IRS May Offer New Amnesty For Offshore Tax Evaders New Charges Against UBS Banker - Business as Usual for the Swiss? Voluntary Disclosure Program - U.S. Taxpayers Can Still File Taxman eyes up Virgin Islands and Panama
You may want to think about participation in the IRS' offshore tax amnesty program (called the Offshore Voluntary Disclosure Initiative). Do you want to play audit roulette with the IRS? Some clients think they are too small to be prosecuted. They are wrong.
To the average businessperson, only the guys with tens of millions secretly stashed in Swiss bank accounts get prosecuted. Don't tell that to Michael Schiavo. He was just prosecuted for hiding money in a Swiss account back in 2003. How much money does the IRS say he hid? A whopping $90,000. That's it.
But wait, there is more to the story. Schiavo attempted to do a quiet disclosure during the 2009 amnesty but instead of filling out the amnesty paperwork, he simply trusted that by coming forward voluntarily he could avoid criminal prosecution. He was wrong on all counts. Nothing is too small for the IRS, and nothing is too old.
"So, to save a whopping $40,624 in taxes, this guy risked a felony conviction and prison time, not to mention steep penalties that could very easily eat up the entire $90,000, and also his criminal and civil defense costs.
The smart taxpayers are the ones coming forward and not having to look over their shoulders for the next 10 years.
Time is running out. The tax amnesty runs through August but it takes at least days to jump through all the hoops. We will also fight hard to reduce the penalties down even more. Remember, the IRS can go as low as 5%. Don't want this to happen to you? Visit taxadvisorexpert.com today!
Lance Wallach, National Society of Accountants Speaker of the Year and member of the AICPA faculty of teaching professionals, is a frequent speaker on retirement plans, financial and estate planning, and abusive tax shelters. He writes about 412(i), 419, and captive insurance plans. He speaks at more than ten conventions annually, writes for over fifty publications, is quoted regularly in the press and has been featured on television and radio financial talk shows including NBC, National Pubic Radio's All Things Considered, and others. Lance has written numerous books including Protecting Clients from Fraud, Incompetence and Scams published by John Wiley and Sons, Bisk Education's CPA's Guide to Life Insurance and Federal Estate and Gift Taxation, as well as AICPA best-selling books, including Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots. He does expert witness testimony and has never lost a case. Contact him at 516.938.5007, wallachinc@gmail.com or visit www.taxaudit419.com.
The information provided herein is not intended as legal, accounting, financial or any type of advice for any specific individual or other entity. You should contact an appropriate professional for any such advice.
FBAR Offshore Bank Accounts and Foreign Income Attacked by IRS
Aug 10, 20110150 41
Offshore International Today Aug 2011
Lance Wallach
RELATED ARTICLES IRS May Offer New Amnesty For Offshore Tax Evaders New Charges Against UBS Banker - Business as Usual for the Swiss? Voluntary Disclosure Program - U.S. Taxpayers Can Still File Taxman eyes up Virgin Islands and Panama
You may want to think about participation in the IRS' offshore tax amnesty program (called the Offshore Voluntary Disclosure Initiative). Do you want to play audit roulette with the IRS? Some clients think they are too small to be prosecuted. They are wrong.
To the average businessperson, only the guys with tens of millions secretly stashed in Swiss bank accounts get prosecuted. Don't tell that to Michael Schiavo. He was just prosecuted for hiding money in a Swiss account back in 2003. How much money does the IRS say he hid? A whopping $90,000. That's it.
But wait, there is more to the story. Schiavo attempted to do a quiet disclosure during the 2009 amnesty but instead of filling out the amnesty paperwork, he simply trusted that by coming forward voluntarily he could avoid criminal prosecution. He was wrong on all counts. Nothing is too small for the IRS, and nothing is too old.
"So, to save a whopping $40,624 in taxes, this guy risked a felony conviction and prison time, not to mention steep penalties that could very easily eat up the entire $90,000, and also his criminal and civil defense costs.
The smart taxpayers are the ones coming forward and not having to look over their shoulders for the next 10 years.
Time is running out. The tax amnesty runs through August but it takes at least days to jump through all the hoops. We will also fight hard to reduce the penalties down even more. Remember, the IRS can go as low as 5%. Don't want this to happen to you? Visit taxadvisorexpert.com today!
Lance Wallach, National Society of Accountants Speaker of the Year and member of the AICPA faculty of teaching professionals, is a frequent speaker on retirement plans, financial and estate planning, and abusive tax shelters. He writes about 412(i), 419, and captive insurance plans. He speaks at more than ten conventions annually, writes for over fifty publications, is quoted regularly in the press and has been featured on television and radio financial talk shows including NBC, National Pubic Radio's All Things Considered, and others. Lance has written numerous books including Protecting Clients from Fraud, Incompetence and Scams published by John Wiley and Sons, Bisk Education's CPA's Guide to Life Insurance and Federal Estate and Gift Taxation, as well as AICPA best-selling books, including Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots. He does expert witness testimony and has never lost a case. Contact him at 516.938.5007, wallachinc@gmail.com or visit www.taxaudit419.com.
The information provided herein is not intended as legal, accounting, financial or any type of advice for any specific individual or other entity. You should contact an appropriate professional for any such ad
That's pretty much the headline from a CNBC article on Friday. And it's true.
In 2009, 15,000 Americans came forward and admitted having foreign bank accounts. Unfortunately, Uncle Sam estimates there are some 500,000 more people hiding money offshore. Opening a bank account in another country isn't illegal. There are a whole host of reasons why people may wish to send money offshore. It only becomes illegal when you send money to a foreign country in the hopes of cheating Uncle Sam.
U.S. law makes it a felony if you fail to declare the income from foreign investments on your U.S. tax return and makes it illegal to not disclose the existence of the foreign account.
So what is a person to do? Taxpayers can do nothing and hope they don't lose the "audit lottery" (there are no winners with the IRS). Or taxpayers can come into compliance, report the account and pay the government ¼ of the highest dollar amount that was in the account. That's right, if you had an account with $20
Abusive Tax Shelters & 419 Plans Lawsuits 412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.
Tuesday, March 18, 2014
FBAR/OVDI LANCE WALLACH: FBAR-What are You Hiding FBAR/OVDI LANCE WALLACH: FBAR-What are You Hiding: The collapse of Swiss bank secrecy, the IRS settlement with UBS, the criminal investigation of HSBC and the related IRS voluntary disclo...
This article gives the light in which we can observe the reality. This is very nice one and gives indepth information. Thanks for this nice article. bulletproof hosting provider
ReplyDeleteFBAR/OVDI LANCE WALLACH
FBAR Foreign Bank Account Reporting The IRS is assessing huge penalties for undisclosed foreign bank accounts, assets & income. Click for more info FBAR FILING DEADLING HAS BEEN EXTENDED
Tuesday, August 20, 2013
FBAR & INT'L Tax Report!
Need Help With Your Foreign Bank Account?
Click Link Below Free FBAR & INT'L Tax Alert report
http://lawyer4audits.com/fbar-ovdi-international.html
Posted by Lance Wallach at 12:57 PM
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lance wallachMarch 12, 2014 at 3:25 PM
FBAR/OVDI LANCE WALLACH
FBAR Foreign Bank Account Reporting The IRS is assessing huge penalties for undisclosed foreign bank accounts, assets & income. Click for more info FBAR FILING DEADLING HAS BEEN EXTENDED
Tuesday, December 24, 2013
FBAR Offshore Bank Accounts and Foreign Income Attacked by IRS
FBAR Offshore Bank Accounts and Foreign Income Attacked by IRS
Posted by Lance Wallach at 9:19 AM 1 comment:
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As an expert witness, Lance Wallach has never lost a case. Lance Wallach has also written "CPA's guide to life insurance".
Deletehttp://lancewallachchfc.blogspot.com/
https://www.youtube.com/watch?v=WTMWg6bn0Bc
http://multinationaltaxesfbarovdi.blogspot.com/2013/12/fbar-international-tax-alert-report.html?showComment=1397481749542#c7747324770018422953
click the links for more information
Reporting by U.S. Persons Holding Foreign Financi
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www.TaxAudit419.com
www.Vebaplan.org
IRS Form 8938
FATCA requires any U.S. person holding foreign financial assets with an aggregate value exceeding $50,000 to report certain information about those assets on a new form (Form 8938) that must be attached to the taxpayer’s annual tax return. Reporting applies for assets held in taxable years beginning on or after January 1, 2011. Failure to report foreign financial assets on Form 8938 will result in a penalty of $10,000 (and a penalty up to $50,000 for continued failure after IRS notification). Further, underpayments of tax attributable to non-disclosed foreign financial assets will be subject to an additional substantial understatement penalty of 40 percent.
Under FATCA, U.S. taxpayers holding financial assets outside the United States must report those assets to the IRS on a new form attached to their tax return. Penalties apply for failure to comply with this new reporting requirement. Reporting is required for assets held in taxable years beginning on or after January 1
The Tax Audit Pros
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Lance Wallach
More Credentials:
National Society of Accountants
Speaker of the Year and member of
the
AICPA faculty of teaching
professionals
Frequent speaker on retirement
plans, financial and estate planning,
and abusive tax shelters.
Writes about 412(i), 419, and
captive insurance plans.
Speaks at more than ten
conventions annually
Writes for more than fifty
publications
Is quoted regularly in the press and
has been featured on television and
radio financial talk shows including
NBC, National Pubic Radio's All
Things Considered, and others.
Author of Protecting Clients from
Fraud, Incompetence and Scams
published by John Wiley and Sons
Author of Bisk Education's CPA's
Guide to Life Insurance and
Federal Estate and Gift Taxation.
Author of AICPA best-selling
books, including Avoiding Circular
230 Malpractice Traps and
Common Abusive Small Business
Hot Spots.
Lance Wallach publishes extensively on this
subject - something the authorities look for
in an Expert Witness:
Get Sued!
Small Business and Retirement Plans Fuel
Litigation
Advisors Staring at a New "Slew" of
Litigation from Small Business Clients
IRS Says Most 419 Plans are Abusive Tax
Shelters
Call
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TODAY!
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penalties you should know that when
Lance Wallach was on a team.........
His side never lost a case!
Due to recent changes in "IRS regulations",
both participants and their "material advisors"
can be subject to large "IRS tax penalties"! The
IRS is auditing many of these "benefit plans"
right
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ReplyDelete412i 419 sect 79 lawsuits audits www.lancewallach.com for help (plainview)
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Lance Wallach helps with 419 problems. 412i 419 abusive tax shelters IRS audits, lawsuits, Lance Wallach will help www.vebaplan.com
419, 412i, IRS audits, Lance Wallach, Google him helps, The following had something to do with this.
Dennis Cunning Steve Toth Randall Smith Paul Kaplan Herb Green Casey Hermansen
Larry Bell Scott Ridge Judy Carsrud Jeffrey Glasberg Herb McDowel
Greg Roper Joseph Donnelly
Norm Bevan Michael Sonnenberg
Dan Carpenter Anthony Fakouri
Steve Burgess
Robin Weingast
IRS audits 419 412i captive insurance and section 79 plans. Lance Wallach will help you.
IRS audits section 79 419 412i plans. www.lancewallach.com for help
Benistar, IRS raids, Niche, Robin Weingast, Lance Wallach helps, Sadi trust, grist Mill trust, nova 419 welfare benefit plan problems and how Lance Wallach helps.www.vebaplan.com for more help. Sea Nine VEBA, 419, 412i, IRS audits,Sea Nine VEBA, Benistar, Grist Mill Trust are all audited by the IRS and people in them probably need help.
Sea Nine VEBA, 419,412i are all IRS audit targets. Lance Wallach can help, www.tazaudit419.com
419, 412i, IRS audits, Lance Wallach, Google him helps, The following had something to do with this. Author to write about these problems.
Dennis Cunning Steve Toth Randall Smith Paul Kaplan Herb Green Casey Hermansen
Larry Bell Scott Ridge Judy Carsrud Jeffrey Glasberg Herb McDowel
Greg Roper Joseph Donnelly
Norm Bevan Michael Sonnenberg
Dan Carpenter Anthony Fakouri
Steve Burgess
Robin Weingast
"SADI Trust" Lance Wallach will help fix the problems that people have that are or were in the plans.
"Professional Benefits Trust" PBI
"Sea Nine Veba"
Bisys
The "Beta Plan"
The "Millennium Plan"
Benistar
Niche
The "Ridge Plan"
The "Grist Mill Trust"
The "Compass Welfare Benefit Plan"
"Section 79 Plans"
"Captive Insurance"
and other similar "412i retirement plans" and "419 welfare benefit plans
Lance Wallach, www.taxaudit419.com will help you with these problems and more like section 79, captive insurance lawsuits and IRS audits. People in the section 79 plans 419 welfare benefit plans captive insurance and 412i pension plans are getting audited by the IRS and then they sue. Google Lance Wallach for help with this. If you need help Lance Wallach as an expert witness has never lost a case. You need help NOW.
Customers of James Cunningham d/b/a Cunningham Financial or CFG Consulting LLC? We want to speak with you!
IRS audits and lawsuits result from 419 412i captive insurance and section 79 plans. As an expert witness Lance Wallach has never lost a case.
Lance Wallach | blinkbox books
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We're not usually lost for words, but on this occasion we have to confess that we don't have all the author's details at the moment. We hope to have more details ...
FBAR/OVDI LANCE WALLACH: FBAR-What are You Hiding
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Chapter 1 - Planning for Business Owners
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Material Advisors & 419 Plans Litigation
ReplyDelete412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.
Tuesday, February 28, 2012
Lance Wallach National Society of Accountants Speaker of The Year
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Lance WallachJuly 31, 2013 at 8:31 AM
412i IRS audits, listed transactions
________________________________________
April 24, 2012 By Lance Wallach, CLU, CHFC
________________________________________
IRS auditing 412i plans
Protecting Clients From Fraud, Incompetence, and Scams
By: Lance Wallach
Published by John Wiley and Sons, Inc.
Copyright Ó 2010. All rights reserved.
Excerpts have been taken f
412i-419 Plans
ReplyDelete419 & 412i benefit plan,abusive tax shelters, Lance Wallach Expert Witness
Wednesday, March 12, 2014
FBAR/OVDI LANCE WALLACH: FBAR Offshore Bank Accounts and Foreign Income Att...
FBAR/OVDI LANCE WALLACH: FBAR Offshore Bank Accounts and Foreign Income Att...: FBAR Offshore Bank Accounts and Foreign Income Attacked by IRS
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Captive Insurance & 419 Plans Litigation
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Feb 27, 2014 - By Lance Wallach, Consultant & Expert Witness. Recent court cases have highlighted serious problems in welfare benefit plans issued by Nova
FBAR/OVDI LANCE WALLACH
ReplyDeleteFBAR Foreign Bank Account Reporting The IRS is assessing huge penalties for undisclosed foreign bank accounts, assets & income. Click for more info FBAR FILING DEADLING HAS BEEN EXTENDED
Thursday, December 5, 2013
FBAR & International Tax Alert Report
The willful failure to file the FBAR report or retain records of your foreign accounts can potentially lead to a ten-year prison sentence and fines of up to $500,000. This criminal penalty applies to all US citizens pursuant to 31U.S.C Section S322B and 31 C.F.R. Section 103.S.9.C It may also apply to persons living in the United States who are not citizens.
If you fail to answer the question truthfully on schedule B of your Form 1040 which asks if you “have an interest in or a signature or other authority over a financial account in a foreign country”, then your false statement might be deemed a criminal offense by the IRS per the sections mentioned above if other surrounding facts and circumstances apply.
Our office is headed by a former international tax IRS agent with 37 years experience as a CPA and Associate Professor of accounting. Call our office immediately for a free five-minute consultation so you can avoid the dire circumstances described above and deal with the other associated problems.
516-938-5007
TaxAdvisorExpert.com
FBAR/OVDI LANCE WALLACH
ReplyDeleteFBAR Foreign Bank Account Reporting The IRS is assessing huge penalties for undisclosed foreign bank accounts, assets & income. Click for more info FBAR FILING DEADLING HAS BEEN EXTENDED
First, since 2009 there have been three (3) formal opportunities for U.S. taxpayers to come forward. There was the 2009, 2011, 2012 and now the 2013 programs.
Second, offshore banks have been sending out letters to U.S. based account holders requesting that they attest to compliance with FBAR reporting and closing some accounts for non-compliance. The due diligence provisions Foreign Account Tax Compliance Act (FATCA) are now in effect and offshore banks with U.S. correspondent banking agreements are scouring their records for U.S. account holders. These banks are requesting consent from U.S. account holders to disclose information about the U.S. account holder to the IRS.
Third, The Justice Department has brought actions against several offshore banks, Switzerland, Luxembourg, and Israel to compel disclosure of information about U.S. account holders.
Finally, beginning with 2011, Form 1040 has specific questions on Schedule B about whether the taxpayer filed an FBAR. Yet, in spite of all of the information many U.S. taxpayers, including those who are resident aliens have refused to come forward. Some of the reasons for not coming forward are fear based, and some based upon risk/reward estimates. In each case the outcome if caught is so terrible, that it is hard to imagine why anyone would refuse to come forward.
However, in the following situations it is overwhelmingly likely that you will caught – and as in most things of this nature, the consequences will largely be determined by who gets to whom first:
Example 1: Taxpayers are resident aliens who claim to have inherited funds in excess of $100,000 somewhat recently. The funds were kept in an offshore account and not reported for either income tax or FBAR purposes. Here are the potential results. First, a Report of Foreign Gift or Bequest was due for income tax purposes. While no estate or gift tax was due the failure to file Form 3520 when due can result in a civil penalty of between 25% -35% of the amount of the bequest, (for simply not filing). If the taxpayers filed an FBAR and Form 3520 timely there would be no penalties at all and no tax due Second, the taxpayer's now face a civil FBAR penalty of the greater of 50% or $100,000 of the highest account balance per year. If, however, they enter the offshore voluntary disclosure program the maximum combined civil penalty is 27.5% of the highest single year account balance. While the civil penalty is costly, the "ostrich" approach is likely to be catastrophic.
FBAR/OVDI LANCE WALLACH
ReplyDeleteFBAR Foreign Bank Account Reporting The IRS is assessing huge penalties for undisclosed foreign bank accounts, assets & income. Click for more info FBAR FILING DEADLING HAS BEEN EXTENDED
Thursday, June 20, 2013
Foreign Bank Account Report, Treasury Department Form 90-22.1 (FBAR)
Who Must File an FBAR:
Generally, every U.S. person with a financial interest in or signature or other authority over, any financial account outside of the United States, must file an FBAR if the aggregate value of all accounts exceeds $10,000 at any time during the calendar year. An FBAR must be filed by U.S. taxpayers that have signature authority over any account, even if they have no financial interest in or are not the owner of the account. Such accounts include but are not limited to: bank, securities, pension funds, other financial accounts, any accounts with commingled funds, any accounts held by entities for which the individual is a shareholder/owner, etc.
FBAR Filing Deadline:
The FBAR must be received on or before June 30th of the year following the calendar year being reported. It is not filed with your federal tax return. June 30, 2012 falls on a Saturday this year, but there has been no official announcement that individuals will not face late filing penalties if the FBAR is not received by the deadline. Therefore it may be prudent to file so that it is received by June 29, 2012.
There are three (3) pages of instructions and information as to the specific form and instructions can be found on irs.gov and/or bsaefiling.fincen.treas.gov. It should be noted that the information provided on these sites (as well as this site) should not be construed as legal advice.
How FBAR information can be used:
The information collected by the reporting can be provided to officers and employees of any division of the Treasury Department. These records may be utilized in performance of their duties and investigations as well as referred to other federal, state or local authority upon request for use in criminal, tax, regulatory investigation or proceeding, or other investigations and matters.
Do you need an attorney for FBAR issues?
If you have never filed an FBAR but should have --> you should immediately consult with a tax attorney familiar with international tax law or with a CPA that was with the IRS division of international tax.
If you are concerned about how the information will be used or could be used against you --> you should immediately consult with a tax attorney familiar with international tax law and financial/white collar crime defense or with an ex IRS official who is a CPA.
If you filed an incomplete or false FBAR --> you should immediately consult with a tax attorney who is familiar with international tax law and financial/white collar crime defense or with a CPA that was with the international division of the IRS.
How to get your tax law questions answered - confidentially:
You may wish to consult with an experienced tax attorney or with an ex IRS agent before filing the FBAR form or any other financial document that is requested or required of you because a seemingly simple form (admittedly, financial forms are never "that" simple) have far reaching consequences that can come back to haunt you
FBAR Offshore Bank Accounts and Foreign Income Attacked by IRS
ReplyDeleteAug 10, 20110149
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Offshore International Today Aug 2011
Lance Wallach
RELATED ARTICLES
IRS May Offer New Amnesty For Offshore Tax Evaders
New Charges Against UBS Banker - Business as Usual for the Swiss?
Voluntary Disclosure Program - U.S. Taxpayers Can Still File
Taxman eyes up Virgin Islands and Panama
You may want to think about participation in the IRS' offshore tax amnesty program (called the Offshore Voluntary Disclosure Initiative). Do you want to play audit roulette with the IRS? Some clients think they are too small to be prosecuted. They are wrong.
To the average businessperson, only the guys with tens of millions secretly stashed in Swiss bank accounts get prosecuted. Don't tell that to Michael Schiavo. He was just prosecuted for hiding money in a Swiss account back in 2003. How much money does the IRS say he hid? A whopping $90,000. That's it.
But wait, there is more to the story. Schiavo attempted to do a quiet disclosure during the 2009 amnesty but instead of filling out the amnesty paperwork, he simply trusted that by coming forward voluntarily he could avoid criminal prosecution. He was wrong on all counts. Nothing is too small for the IRS, and nothing is too old.
"So, to save a whopping $40,624 in taxes, this guy risked a felony conviction and prison time, not to mention steep penalties that could very easily eat up the entire $90,000, and also his criminal and civil defense costs.
The smart taxpayers are the ones coming forward and not having to look over their shoulders for the next 10 years.
Time is running out. The tax amnesty runs through August but it takes at least days to jump through all the hoops. We will also fight hard to reduce the penalties down even more. Remember, the IRS can go as low as 5%. Don't want this to happen to you? Visit taxadvisorexpert.com today!
Lance Wallach, National Society of Accountants Speaker of the Year and member of the AICPA faculty of teaching professionals, is a frequent speaker on retirement plans, financial and estate planning, and abusive tax shelters. He writes about 412(i), 419, and captive insurance plans. He speaks at more than ten conventions annually, writes for over fifty publications, is quoted regularly in the press and has been featured on television and radio financial talk shows including NBC, National Pubic Radio's All Things Considered, and others. Lance has written numerous books including Protecting Clients from Fraud, Incompetence and Scams published by John Wiley and Sons, Bisk Education's CPA's Guide to Life Insurance and Federal Estate and Gift Taxation, as well as AICPA best-selling books, including Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots. He does expert witness testimony and has never lost a case. Contact him at 516.938.5007, wallachinc@gmail.com or visit www.taxaudit419.com.
.
ReplyDeleteReporting by U.S. Persons Holding Foreign Financi
Contact Information
Email :
Lanwalla@aol.com
Phone :
516-983-5007
Address :
Lance Wallach
www.TaxAudit419.com
www.Vebaplan.org
IRS Form 8938
FATCA requires any U.S. person holding foreign financial assets with an aggregate value exceeding $50,000 to report certain information about those assets on a new form (Form 8938) that must be attached to the taxpayer’s annual tax return. Reporting applies for assets held in taxable years beginning on or after January 1, 2011. Failure to report foreign financial assets on Form 8938 will result in a penalty of $10,000 (and a penalty up to $50,000 for continued failure after IRS notification). Further, underpayments of tax attributable to non-disclosed foreign financial assets will be subject to an additional substantial understatement penalty of 40 percent.
Under FATCA, U.S. taxpayers holding financial assets outside the United States must report those assets to the IRS on a new form attached to their tax return. Penalties apply for failure to comply with this new reporting requirement. Reporting is required for assets held in taxable years beginning on or after January 1
Why is it so dangerous to get it wrong?
ReplyDeleteThe FBAR form is a informational return that any US taxpayer who owns or controls foreign financial accounts that exceed $10,000.00 in total must file with the IRS every June, regardless if an extension to file a 1040 was filed or not. The FBAR is not sent in with form 1040, but rather, to an address in Detroit. The complications and strange rules of the FBAR are best explained by explaining the evolution of the form, and law and regulations that changed along the way.
FBAR Offshore Bank Accounts and Foreign Income Attacked by IRS
ReplyDeleteAug 10, 20110149
17
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Offshore International Today Aug 2011
Lance Wallach
RELATED ARTICLES
IRS May Offer New Amnesty For Offshore Tax Evaders
New Charges Against UBS Banker - Business as Usual for the Swiss?
Voluntary Disclosure Program - U.S. Taxpayers Can Still File
Taxman eyes up Virgin Islands and Panama
You may want to think about participation in the IRS' offshore tax amnesty program (called the Offshore Voluntary Disclosure Initiative). Do you want to play audit roulette with the IRS? Some clients think they are too small to be prosecuted. They are wrong.
To the average businessperson, only the guys with tens of millions secretly stashed in Swiss bank accounts get prosecuted. Don't tell that to Michael Schiavo. He was just prosecuted for hiding money in a Swiss account back in 2003. How much money does the IRS say he hid? A whopping $90,000. That's it.
But wait, there is more to the story. Schiavo attempted to do a quiet disclosure during the 2009 amnesty but instead of filling out the amnesty paperwork, he simply trusted that by coming forward voluntarily he could avoid criminal prosecution. He was wrong on all counts. Nothing is too small for the IRS, and nothing is too old.
"So, to save a whopping $40,624 in taxes, this guy risked a felony conviction and prison time, not to mention steep penalties that could very easily eat up the entire $90,000, and also his criminal and civil defense costs.
The smart taxpayers are the ones coming forward and not having to look over their shoulders for the next 10 years.
Time is running out. The tax amnesty runs through August but it takes at least days to jump through all the hoops. We will also fight hard to reduce the penalties down even more. Remember, the IRS can go as low as 5%. Don't want this to happen to you? Visit taxadvisorexpert.com today!
Lance Wallach, National Society of Accountants Speaker of the Year and member of the AICPA faculty of teaching professionals, is a frequent speaker on retirement plans, financial and estate planning, and abusive tax shelters. He writes about 412(i), 419, and captive insurance plans. He speaks at more than ten conventions annually, writes for over fifty publications, is quoted regularly in the press and has been featured on television and radio financial talk shows including NBC, National Pubic Radio's All Things Considered, and others. Lance has written numerous books including Protecting Clients from Fraud, Incompetence and Scams published by John Wiley and Sons, Bisk Education's CPA's Guide to Life Insurance and Federal Estate and Gift Taxation, as well as AICPA best-selling books, including Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots. He does expert witness testimony and has never lost a case. Contact him at 516.938.5007, wallachinc@gmail.com or visit www.taxaudit419.com.
The information provided herein is not intended as legal, accounting, financial or any type of advice for any specific individual or other entity. You should contact an appropriate professional for any such advice
FBAR_OVDI & 419 Plans Litigation
ReplyDeleteFBAR,OVDI,OPT-OUT,AMNESTY412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.
Tuesday, September 4, 2012
IRS: Disclose Offshore Accounts or Go to Jail
IRS: Disclose Offshore Accounts or Go to Jail
Brian
That's pretty much the headline from a CNBC article on Friday. And it's true.
In 2009, 15,000 Americans came forward and admitted having foreign bank accounts. Unfortunately, Uncle Sam estimates there are some 500,000 more people hiding money offshore. Opening a bank account in another country isn't illegal. There are a whole host of reasons why people may wish to send money offshore. It only becomes illegal when you send money to a foreign country in the hopes of cheating Uncle Sam.
Reply
FBAR Offshore Bank Accounts and Foreign Income Attacked by IRS
ReplyDeleteAug 10, 20110149
17
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Offshore International Today Aug 2011
Lance Wallach
RELATED ARTICLES
IRS May Offer New Amnesty For Offshore Tax Evaders
New Charges Against UBS Banker - Business as Usual for the Swiss?
Voluntary Disclosure Program - U.S. Taxpayers Can Still File
Taxman eyes up Virgin Islands and Panama
You may want to think about participation in the IRS' offshore tax amnesty program (called the Offshore Voluntary Disclosure Initiative). Do you want to play audit roulette with the IRS? Some clients think they are too small to be prosecuted. They are wrong.
To the average businessperson, only the guys with tens of millions secretly stashed in Swiss bank accounts get prosecuted. Don't tell that to Michael Schiavo. He was just prosecuted for hiding money in a Swiss account back in 2003. How much money does the IRS say he hid? A whopping $90,000. That's it.
But wait, there is more to the story. Schiavo attempted to do a quiet disclosure during the 2009 amnesty but instead of filling out the amnesty paperwork, he simply trusted that by coming forward voluntarily he could avoid criminal prosecution. He was wrong on all counts. Nothing is too small for the IRS, and nothing is too old.
"So, to save a whopping $40,624 in taxes, this guy risked a felony conviction and prison time, not to mention steep penalties that could very easily eat up the entire $90,000, and also his criminal and civil defense costs.
The smart taxpayers are the ones coming forward and not having to look over their shoulders for the next 10 years.
Time is running out. The tax amnesty runs through August but it takes at least days to jump through all the hoops. We will also fight hard to reduce the penalties down even more. Remember, the IRS can go as low as 5%. Don't want this to happen to you? Visit taxadvisorexpert.com today!
Lance Wallach, National Society of Accountants Speaker of the Year and member of the AICPA faculty of teaching professionals, is a frequent speaker on retirement plans, financial and estate planning, and abusive tax shelters. He writes about 412(i), 419, and captive insurance plans. He speaks at more than ten conventions annually, writes for over fifty publications, is quoted regularly in the press and has been featured on television and radio financial talk shows including NBC, National Pubic Radio's All Things Considered, and others. Lance has written numerous books including Protecting Clients from Fraud, Incompetence and Scams published by John Wiley and Sons, Bisk Education's CPA's Guide to Life Insurance and Federal Estate and Gift Taxation, as well as AICPA best-selling books, including Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots. He does expert witness testimony and has never lost a case. Contact him at 516.938.5007, wallachinc@gmail.com or visit www.taxaudit419.com.
The information provided herein is not intended as legal, accounting, financial or any type of advice for any specific individual or other entity. You should contact an appropriate professional for any such advice
FBAR Offshore Bank Accounts and Foreign Income Attacked by IRS
ReplyDeleteAug 10, 20110149
17
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Offshore International Today Aug 2011
Lance Wallach
RELATED ARTICLES
IRS May Offer New Amnesty For Offshore Tax Evaders
New Charges Against UBS Banker - Business as Usual for the Swiss?
Voluntary Disclosure Program - U.S. Taxpayers Can Still File
Taxman eyes up Virgin Islands and Panama
You may want to think about participation in the IRS' offshore tax amnesty program (called the Offshore Voluntary Disclosure Initiative). Do you want to play audit roulette with the IRS? Some clients think they are too small to be prosecuted. They are wrong.
To the average businessperson, only the guys with tens of millions secretly stashed in Swiss bank accounts get prosecuted. Don't tell that to Michael Schiavo. He was just prosecuted for hiding money in a Swiss account back in 2003. How much money does the IRS say he hid? A whopping $90,000. That's it.
But wait, there is more to the story. Schiavo attempted to do a quiet disclosure during the 2009 amnesty but instead of filling out the amnesty paperwork, he simply trusted that by coming forward voluntarily he could avoid criminal prosecution. He was wrong on all counts. Nothing is too small for the IRS, and nothing is too old.
"So, to save a whopping $40,624 in taxes, this guy risked a felony conviction and prison time, not to mention steep penalties that could very easily eat up the entire $90,000, and also his criminal and civil defense costs.
The smart taxpayers are the ones coming forward and not having to look over their shoulders for the next 10 years.
Time is running out. The tax amnesty runs through August but it takes at least days to jump through all the hoops. We will also fight hard to reduce the penalties down even more. Remember, the IRS can go as low as 5%. Don't want this to happen to you? Visit taxadvisorexpert.com today!
Lance Wallach, National Society of Accountants Speaker of the Year and member of the AICPA faculty of teaching professionals, is a frequent speaker on retirement plans, financial and estate planning, and abusive tax shelters. He writes about 412(i), 419, and captive insurance plans. He speaks at more than ten conventions annually, writes for over fifty publications, is quoted regularly in the press and has been featured on television and radio financial talk shows including NBC, National Pubic Radio's All Things Considered, and others. Lance has written numerous books including Protecting Clients from Fraud, Incompetence and Scams published by John Wiley and Sons, Bisk Education's CPA's Guide to Life Insurance and Federal Estate and Gift Taxation, as well as AICPA best-selling books, including Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots. He does expert witness testimony and has never lost a case. Contact him at 516.938.5007, wallachinc@gmail.com or visit www.taxaudit419.com.
The information provided herein is not intended as legal, accounting, financial or any type of advice for any specific individual or other entity. You should contact an appropriate professional for any such advice.
FBAR Offshore Bank Accounts and Foreign Income Attacked by IRS
ReplyDeleteAug 10, 20110150
41
Offshore International Today Aug 2011
Lance Wallach
RELATED ARTICLES
IRS May Offer New Amnesty For Offshore Tax Evaders
New Charges Against UBS Banker - Business as Usual for the Swiss?
Voluntary Disclosure Program - U.S. Taxpayers Can Still File
Taxman eyes up Virgin Islands and Panama
You may want to think about participation in the IRS' offshore tax amnesty program (called the Offshore Voluntary Disclosure Initiative). Do you want to play audit roulette with the IRS? Some clients think they are too small to be prosecuted. They are wrong.
To the average businessperson, only the guys with tens of millions secretly stashed in Swiss bank accounts get prosecuted. Don't tell that to Michael Schiavo. He was just prosecuted for hiding money in a Swiss account back in 2003. How much money does the IRS say he hid? A whopping $90,000. That's it.
But wait, there is more to the story. Schiavo attempted to do a quiet disclosure during the 2009 amnesty but instead of filling out the amnesty paperwork, he simply trusted that by coming forward voluntarily he could avoid criminal prosecution. He was wrong on all counts. Nothing is too small for the IRS, and nothing is too old.
"So, to save a whopping $40,624 in taxes, this guy risked a felony conviction and prison time, not to mention steep penalties that could very easily eat up the entire $90,000, and also his criminal and civil defense costs.
The smart taxpayers are the ones coming forward and not having to look over their shoulders for the next 10 years.
Time is running out. The tax amnesty runs through August but it takes at least days to jump through all the hoops. We will also fight hard to reduce the penalties down even more. Remember, the IRS can go as low as 5%. Don't want this to happen to you? Visit taxadvisorexpert.com today!
Lance Wallach, National Society of Accountants Speaker of the Year and member of the AICPA faculty of teaching professionals, is a frequent speaker on retirement plans, financial and estate planning, and abusive tax shelters. He writes about 412(i), 419, and captive insurance plans. He speaks at more than ten conventions annually, writes for over fifty publications, is quoted regularly in the press and has been featured on television and radio financial talk shows including NBC, National Pubic Radio's All Things Considered, and others. Lance has written numerous books including Protecting Clients from Fraud, Incompetence and Scams published by John Wiley and Sons, Bisk Education's CPA's Guide to Life Insurance and Federal Estate and Gift Taxation, as well as AICPA best-selling books, including Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots. He does expert witness testimony and has never lost a case. Contact him at 516.938.5007, wallachinc@gmail.com or visit www.taxaudit419.com.
The information provided herein is not intended as legal, accounting, financial or any type of advice for any specific individual or other entity. You should contact an appropriate professional for any such ad
FBAR_OVDI
ReplyDeleteFBAR_OVDI_Lance Wallach_
Tuesday, December 11, 2012
IRS: Disclose Offshore Accounts or Go to Jail
Brian M
That's pretty much the headline from a CNBC article on Friday. And it's true.
In 2009, 15,000 Americans came forward and admitted having foreign bank accounts. Unfortunately, Uncle Sam estimates there are some 500,000 more people hiding money offshore. Opening a bank account in another country isn't illegal. There are a whole host of reasons why people may wish to send money offshore. It only becomes illegal when you send money to a foreign country in the hopes of cheating Uncle Sam.
U.S. law makes it a felony if you fail to declare the income from foreign investments on your U.S. tax return and makes it illegal to not disclose the existence of the foreign account.
So what is a person to do? Taxpayers can do nothing and hope they don't lose the "audit lottery" (there are no winners with the IRS). Or taxpayers can come into compliance, report the account and pay the government ¼ of the highest dollar amount that was in the account. That's right, if you had an account with $20
Abusive Tax Shelters & 419 Plans Lawsuits
ReplyDelete412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.
Tuesday, March 18, 2014
FBAR/OVDI LANCE WALLACH: FBAR-What are You Hiding
FBAR/OVDI LANCE WALLACH: FBAR-What are You Hiding: The collapse of Swiss bank secrecy, the IRS settlement with UBS, the criminal investigation of HSBC and the related IRS voluntary disclo...
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