Blog Profile / Tax Problem Attorney Blog

Filed Under:Business & Finance / Taxes
Posts on Regator:238
Posts / Week:0.7
Archived Since:March 8, 2011

Blog Post Archive

What is a “Financial Interest” in a Foreign Accounts for FBAR Purposes?

Any United States person with a financial interest in or signature authority over a foreign financial account, where the aggregate value of all foreign financial accounts exceeds $10,000 at any point during the year, must file a Foreign Bank Account Report (FBAR). These terms can be difficult to apply in some situations, and can lead […]

The Tax Consequences of Inheriting Foreign Assets

U.S. taxpayers who inherit foreign assets must handle the tax consequences of their inheritances with great care. In addition to taxing all worldwide income, the U.S. also includes foreign assets in the gift and estate tax calculation, which determines whether estate tax will be assessed. Heirs who receive foreign assets also have to consider their […]

What Is the Statute of Limitations for FBAR Penalties?

The IRS has six years from the due date of the FBAR to assess the FBAR penalty. In addition, the IRS can assess a separate penalty for each unreported account for each tax year that an FBAR has not been filed, causing the total amount of penalties to add up quickly for some taxpayers. The […]

How Does the IRS Collect FBAR Penalties?

The IRS imposes severe penalties on taxpayers who fail to file a Report of Foreign Bank and Financial Accounts (FBAR). Those who are required to file an FBAR and fail to do so can face the following penalties: a civil penalty not to exceed $12,459 per violation for non-willful violations that are not due to […]

Former IRS Revenue Officer Gets Prison Time for Tax Evasion

A former IRS revenue officer used his knowledge of the tax system to evade more than $573,000 in taxes over a 16-year period. Henti Lucian Baird hid his income—which was ironically made as a tax consultant—in bank accounts that he created in the names of his children. He has been sentenced to 43 months in […]

Which Option Should You Use to Settle Your Tax Debt?

Choosing the wrong option to settle your tax debt can be a very costly error. If you apply for an installment agreement, when you could have eliminated some of your debt with an Offer in Compromise, it could end up costing you thousands, and you can’t expect the IRS to notify you of your alternative […]

How the IRS Pursues Payroll Tax Collections

Payroll taxes represent both the employer and employee portions of Social Security and Medicare taxes, along with Federal income taxes that are withheld from an employee’s paycheck. The IRS takes an especially hard stance on the failure to remit payroll taxes, and uses aggressive collection efforts when pursuing these delinquent taxes. The Trust Fund Recovery […]

Actions to Take Before You Can Pursue an IRS Tax Settlement

Before attempting to settle your IRS tax debt, there are a few things that every taxpayer should do. While some tax settlement cases can be fairly straightforward, there may be more advanced settlement options available for certain taxpayers, and missing out on these opportunities may prevent you from eliminating significant back taxes, penalties, or interest. […]

Swiss Banker Pleads Guilty to Defrauding the United States with Tax Scheme

A former employee of Credit Suisse bank has pleaded guilty to conspiring to defraud the United States. Susanne D. Rüegg Meier admitted to a tax scheme that allowed U.S. taxpayers to hide their assets in Swiss bank accounts. The plea agreement states that Credit Suisse went to great lengths to assist their clients in evading […]

Do I Need a Tax Audit Defense Lawyer?

The IRS conducts tax audits—referred to as examinations—by mail or in-person. Taxpayers are usually selected either randomly, by computer screening or due to a referral or an audit of a business partner or investor. Taxpayers have the option of working with the examiner directly, or with the assistance of a representative such as a tax […]

What to Do When You Can’t Pay Your Taxes

If you have an upcoming tax payment that you can’t pay, or have delinquent tax debt that is continuing to accrue, you may be tempted to delay filing your taxes. You may also want to avoid responding to any IRS notices you receive because you can’t pay off the tax debt listed on the notice. […]

California Resident Indicted for Hiding Foreign Accounts

A Beverly Hills resident has been indicted on several charges for failing to disclose foreign accounts and then allegedly lying to the IRS Criminal Investigation (CI) unit. The charges faced by Teymour Khoubian include the following: corruptly endeavoring to impede the internal revenue laws filing false tax returns Continue reading

The Options for Resolving a Disagreement With Your IRS Examiner

After an IRS examiner receives your documentation and makes a decision regarding proposed changes to your return, you have several options. You can sign the letter stating that you agree with the proposed changes, and then decide what payment method you would prefer to use, whether paying in full, applying for an installment agreement, or […]

Why Offers in Compromise Get Rejected

The Offer in Compromise (OIC) is an excellent program for potentially eliminating tens of thousands of dollars in tax debt, but first, your offer must be accepted by the IRS. Taxpayers may have seen advertisements promising that their tax debt can be settled for pennies on the dollar with an OIC, but not everyone is […]

How the Franchise Tax Board Collects Delinquent Tax Debt

The California Franchise Tax Board (FTB) has many of the same weapons at its disposal as the IRS when collecting delinquent tax debt, and also has the ability to use information received from the IRS to assess additional tax against you. If the IRS audits your tax return, and the audit results in an increase […]

How to Pursue Settlement with the Board of Equalization

If the Board of Equalization (BOE) conducts a sales and use tax audit on your business, you may face a sales tax liability of tens of thousands of dollars or more. To make matters worse, the BOE can share information with the California Franchise Tax Board and the IRS, resulting in more tax assessments, penalties, […]

What Causes an IRS Tax Audit?

The IRS has several methods of selecting returns for a tax audit. First, returns are identified that may possibly contain incorrect amounts, causing a review of the return by an auditor. If everything on your return checks out, the auditor can accept your return as submitted. If the auditor suspects that something is amiss, your […]

What are Foreign Asset Reporting Requirements?

Taxpayers with foreign financial accounts may have several different reporting requirements, depending the type of account and the amount of funds in the accounts. The first of these requirements comes from the 1040 tax return, specifically Schedule B. Schedule B requires the disclosure or any interest or dividends received by the taxpayer, including interest from […]

How to Appeal a Franchise Tax Board Decision

To appeal a decision by the California Franchise Tax Board (FTB), you must first attempt to use all of your administrative remedies within the FTB. After you have exhausted these procedures, you may appeal your decision by submitting the proper forms by the appropriate deadline. These procedures were handled by the Board of Equalization (BOE), […]

Repatriating Funds: What to Do if You Have Delinquent FBARs

Taxpayers with funds in offshore accounts may wish to repatriate their funds by bringing them back to the U.S. and avoid any future Foreign Bank Account Report (FBAR) compliance issues. While this may prevent any future offshore bank account problems, it does not stop the IRS from discovering any past delinquent FBARs and assessing severe […]

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