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6 comments:

  1. 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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    Labels: FBAR, Foreign Income, IRS, Lance Wallach, Lance Wallach Expert Witness
    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 A

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  2. Wednesday, May 8, 2013
    FBAR QUESTIONS

    Lance Wallach

    Acquired or inherited foreign stock or securities, such as bonds.

    Do I need to report these on Form 8938?

    Foreign stock or securities, if you hold them outside of a financial account, must be reported on Form 8938, provided the value of your specified foreign financial assets is greater than the reporting threshold that applies to you. If you hold foreign stock or securities inside of a financial account, you do not report the stock or securities on Form 8938. For more information regarding the reporting of the holdings of financial accounts, see FAQs 8 and 9.

    I directly hold shares of a U.S. mutual fund that owns foreign stocks and securities.

    Do I need to report the shares of the U.S. mutual fund or the stocks and securities held by the mutual fund on Form 8938?

    If you directly hold shares of a U.S. mutual fund you do not need to report the mutual fund or the holdings of the mutual fund.

    I have a financial account maintained by a U.S. financial institution (including U.S. mutual funds, IRAs and 401(K) Plans) that holds foreign stock and securities.

    Do I need to report the financial account or its holdings?

    You do not need to report a financial account maintained by a U.S. financial institution or its holdings. Examples of financial accounts maintained by U.S. financial institutions include:
    U.S. Mutual fund accounts
    IRAs (traditional or Roth)
    401 (k) retirement plans
    Qualified U.S. retirement plans
    Brokerage accounts maintained by U.S. financial institutions
    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.

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  4. 412i 419 sect 79 lawsuits audits www.lancewallach.com for help (plainview)


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    419, 412i, IRS audits, Lance Wallach, Google him helps, The following had something to do with this. Author to write about these problems.
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    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.

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  5. IRS Logo launch of the first program, more than 45,000 taxpayers have come into compliance voluntarily, paying about $6.5 billion in taxes, interest and penalties.

    The expansion of the streamlined procedures and modifications to OVDP reflect the thoughtful input of the tax community given the growing awareness among U.S. taxpayers of their offshore tax obligations.
    “Through our enforcement efforts and implementation of FATCA, taxpayers are more aware of their obligations, and we believe want to come into compliance,” Koskinen said. “In this rapidly changing environment, we listened to feedback from the tax community as well as the National Taxpayer Advocate about our voluntary programs. We have made important adjustments to provide opportunities for all U.S. taxpayers to come in, including those who are not willfully hiding assets.”
    Streamlined Procedures Expanded
    The changes announced today make key expansions in the streamlined procedures to accommodate a wider group of U.S. taxpayers who have unreported foreign financial accounts.
    The original streamlined procedures announced in 2012 were available only to non-resident, non-filers. Taxpayer submissions were subject to different degrees of review based on the amount of the tax due and the taxpayer’s response to a “risk” questionnaire.
    The expanded streamlined procedures are available to a wider population of U.S. taxpayers living outside the country and, for the first time, to certain U.S. taxpayers residing in the United States. The changes include:
    Eliminating a requirement that the taxpayer have $1,500 or less of unpaid tax per year;
    Eliminating the required risk questionnaire;
    Requiring the taxpayer to certify that previous failures to comply were due to non-willful conduct.
    For eligible U.S. taxpayers residing outside the United States, all penalties will be waived. For eligible U.S. taxpayers residing in the United States, the only penalty will be a miscellaneous offshore penalty equal to 5 percent of the foreign financial assets that gave rise to the tax compliance issue.
    Offshore Voluntary Disclosure Program (OVDP) Modified
    The changes announced today also make important modifications to the OVDP. The changes include:
    Requiring additional information from taxpayers applying to the program;
    Eliminating the existing reduced penalty percentage for certain non-willful taxpayers in light of the expansion of the streamlined procedures;
    Requiring taxpayers to submit all account statements and pay the offshore penalty at the time of the OVDP application;
    Enabling taxpayers to submit voluminous records electronically rather than on paper;
    Increasing the offshore penalty percentage (from 27.5% to 50%) if, before the taxpayer’s OVDP pre-clearance request is submitted, it becomes public that a financial institution where the taxpayer holds an account or another party facilitating the taxpayer’s offshore arrangement is under investigation by the IRS or Department of Justice.
    Full details of the changes to both the streamlined procedures and OVDP can be found on IRS.gov.
    Related Items:
    Offshore Voluntary Disclosure Program
    Statement of IRS Commissioner John Koskinen
    FS-2014-6, IRS Offshore Voluntary Disclosure Efforts Produce $6.5 Billion; 45,000 Taxpayers Participate
    FS-2014-7, Offshore Income and Filing Information for Taxpayers with Offshore Accounts
    Page Last Reviewed or Updated: 18-Jun-2014

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  6. 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.

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