Financial Writing Sample: Tax Amnesty

If you missed the FBAR amnesty deadline for voluntary disclosure of your offshore accounts, there is still hope…if you act now.

SUMMARY: If you have an offshore account and missed the IRS’s Foreign Bank and Financial Accounts (FBAR) amnesty deadline on October 15th, it isn’t too late to have your FBAR tax attorney or FBAR tax resolution specialist draft a voluntary disclosure to mount your offshore account tax evasion defense. FBAR tax penalties can amount to as much as 200-300% of the asset value of the offshore account. So offshore account holders need to get expert tax help from a FBAR tax attorney or FBAR tax resolution specialist as soon as possible to seek FBAR tax penalty abatement to reduce the impact of back tax penalties and criminal implications.There is hope but you need to find an experienced, proven FBAR tax attorney or FBAR tax resolution specialist because these are extremely difficult international law issues and the stakes (your freedom) couldn’t be any higher.

The recent agreement between the Swiss government and the IRS has created a cataclysmic tectonic shift for those holding offshore accounts. The Swiss bank UBS has already given up thousands of offshore account holder names and based the agreement’s annex, thousands more will be publicly revealed if they are suspected of participating in a “scheme of lies.” If that sounds scary to offshore account holders, it is. But there is hope. Only an experienced, proven FBAR tax attorney or FBAR tax resolution specialist can free you from these international tax law issues.  Here’s what you need to know.

Having an offshore account may have seemed like a good idea at one time, but today offshore account holders are waking up to the possibility of spending a decade in an American jail cell. If you are gripped by the fear of offshore account tax evasion charges, you are not alone. A lot of big name financial advisers have created offshore account programs for tens (if not hundreds) of thousands of Americans, and that bad offshore account advice now carries a big back tax bill, severe tax penalties and a ten-year jail term for you, the offshore account holder.

A FBAR tax attorney or FBAR tax resolution specialist can mount an offshore account tax evasion defense citing a number of legitimate reasons to hold an offshore account:

  • It’s not unusual for companies that do business internationally to have offshore accounts.
  • You may work for or partner with an international company that has created an offshore account for you.
  • Investors have used custodial currency-based offshore accounts for decades, as a way to reducing exchange rate friction by keeping investments and forced payouts in their native currency. Your financial team may have created such an account for international stock and currency trading.
  • As an individual maybe you opened an offshore account so you’d have money overseas while traveling or living abroad.
  • Maybe you are just a signatory on an offshore account for relatives who live overseas.
  • Possibly you wanted to protect your money from an untrustworthy spendthrift spouse.
  • There are dozens of other legitimate reasons to hold an offshore account that an experienced FBAR tax attorney or FBAR tax resolution specialist can use to save your bacon.

There is hope (with good FBAR tax help) but you are running out of time. The clock is ticking because the IRS is gunning for you in a major way and your problems are compounding daily…literally. If you are reading this you know you’re already in big tax trouble because…

You missed the offshore account tax deadline. You’re in big trouble.

The IRS’s October 15th voluntary disclosure FBAR amnesty deadline has passed. You may have missed your major opportunity to come clean to the IRS with your offshore account back taxes with a guarantee of no jail time. More than 14,700 Americans with secret offshore accounts took the IRS up on that offer so they wouldn’t face criminal prosecution if they paid FBAR back taxes, interest and reduced civil penalties. According to the IRS, the FBAR amnesty program generated “billions of dollars” in new back tax revenue. If you’re FBAR tax attorney or FBAR tax resolution specialist brokered such a sweet deal for you, great. If not….

The IRS is gunning for offshore account holders.

The IRS has found that the back tax money in offshore accounts is gigantic. The IRS expects to get another $8.5 billion in back taxes over the next few years from offshore account holders just like you. And that is just the tip of the iceberg. The IRS is eying over $100 billion in unpaid FBAR back taxes stashed in offshore accounts. In offshore accounts, the IRS has found a new money tree and they will never ever stop shaking for every penny of back taxes. The new IRS tenacity is why you need someone who is an expert in international tax law.

Based on the billion dollar success of the offshore account FBAR amnesty program, the IRS has staffed up to find those offshore account holders who didn’t take the opportunity to avoid jail time. The IRS has just hired 800 personnel in the United States and bulked up their offices overseas solely for the purpose of tracking down offshore account holders. The perceived back tax “wealth” of offshore account holders has created a perfect storm of IRS zeal. People with offshore accounts who didn’t take the IRS up on their offer are perceived as stupid, rich, arrogant, corrupt and about as politically popular as child molesters. This means you have blown your one official shot for offshore account governmental leniency and now they are going to gleefully hunt you down and publicize any offshore account case they can. Don’t have anything to wear for your perp walk? Run to a FBAR tax attorney or FBAR tax resolution specialist right away to get started on your voluntary disclosure before the IRS comes knocking for all those offshore account back taxes.

If you think that you might get lucky and be small enough to fly under the IRS’s radar, you’d be wrong, again.

Bank secrecy is dead
In the good old days national bank secrecy laws in tax haven countries used to keep offshore account money free from the prying eyes of the IRS. Sadly that is soooo 20th century. Recent headlines have shown that not only will national bank secrecy laws not protect your offshore accounts from the IRS, but the IRS may ALREADY know exactly how much you have stashed in your offshore accounts.

Just one Swiss bank, UBS, has agreed to hand over the account information of 4,450 American offshore account holders to the IRS. The IRS is seeking information on over 52,000 offshore accounts. More offshore account banks and financial intermediaries are cutting their deals with the IRS, serving up your “secret” offshore account on a silver platter. If you think that an offshore “company account” was a safer bet, guess again. The IRS is gunning for those too.

And if the IRS can strong-arm the ultra-secretive Swiss to cough up their prized secret bank account holders, think what the IRS can do to other offshore account financial centers. Emboldened by their success with the Swiss, the IRS is rolling out similar offshore account operations in every financial capital. The IRS has identified accounts in 70 countries on every continent except Antarctica. (Maybe you could hire some some penguins to hold onto your cold cash.)

It is virtually guaranteed that the IRS has you in its sights. Whether they put pressure on the financial institution that helped you set up the offshore account, the offshore account bank itself, the foreign government or even a random whistle blower, the IRS WILL FIND YOU.

Now that the FBAR amnesty deadline has passed, the only way to avoid the wrath of the IRS’s intensified federal crackdown on offshore accounts is contacting a FBAR tax attorney or FBAR tax resolution specialist who can mount an offshore tax evasion defense by drafting a voluntary disclosure agreement. Effective representation means that your FBAR tax attorney or FBAR tax resolution specialist, tax resolution specialist or CPA will take over all communications with the IRS, making the required disclosures, filing FBAR reports and amending tax returns typically for 2003 thru 2008.

First steps:

Here are the first steps to take:

  1. Get together of all your offshore accounts.  Break them down by country.  Some offshore account countries have already opened up all their offshore account books to the IRS, others are in the process of doing so. Those safe offshore account tax havens are an endangered species on the verge of extinction. Don’t join them.
  2. Contact a FBAR tax attorney or FBAR tax resolution specialist. Explain in full detail to your FBAR tax attorney or FBAR tax resolution specialist, who told you to set up these offshore accounts. Include any documentation from your offshore account financial advisors. You will want to show that you were simply following tax advice, not trying to subvert the tax law by using offshore accounts. In short, you want to show that you were not willfully failing to declare foreign income.
  3. Have your FBAR tax attorney or FBAR tax resolution specialist conduct all communication with the IRS. This is not the time for amateur hour. So, how serious is this? Very. Every FBAR  tax attorney will tell you that IRS back tax penalties for offshore accounts are double or triple the amount that is hidden in those accounts. If they believe you acted willfully, you’re looking at 10 years of jail time. If you contact the IRS yourself (something you should never, ever do) an innocent mistake can have severe consequences. For example, if you try to do a voluntary disclosure without a FBAR tax attorney or FBAR tax resolution specialist and you forget to file form 5471, you will be hit with an automatic, immediate, mandatory $10,000 fine. And that’s just one of the many small details an experienced FBAR tax attorney or FBAR tax resolution specialist can catch.

Don’t give up hope. Even if you missed the Oct 15th deadline for voluntary disclosure of offshore accounts, a good FBAR tax attorney or FBAR tax resolution specialist can give you the tax help you need by reducing fines and criminal sanctions. But you need an experienced offshore tax evasion expert to give you tax help, not just any tax attorney or CPA, someone who can help your survive the dangerous waters of international tax law. Battling the IRS on offshore tax evasion charges requires the highest level of international tax law legerdemain. You need to act now. The IRS probably already has your number.


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