According to what I was told, the tax amnesty revenue agents have only just begun looking at civil tax audits, and these are for voluntary disclosures that were made before the IRS issued its tax amnesty guidelines. My guess is that voluntary disclosures being filed now will not undergo a civil tax audits by the IRS for another 6 months.

If you are considering a voluntary disclosure under the IRS tax amnesty program, contact the tax attorneys at Brager Tax Law Group, A P.C. for a consultation. No one should consider contacting the IRS without first having spoken with a qualified tax litigation attorney who understands all of the details of your case.

It is unfortunate that the IRS has chosen to take this draconian stance with respect to the FBAR amnesty. It makes the decision to come forward much more difficult.

Our tax litigation attorneys are currently advising clients with FBAR problems on how to best proceed. If you would like a consultation contact the tax attorneys at Brager Tax Law Group, A P.C.

The treaty must still be approved by the Swiss Parliament. At this point it is not known what effect this will have on the UBS summons enforcement action in Florida in which the Internal Revenue Service is attempting to obtain the names of over 50,000 UBS customers with offshore accounts who may have committed tax fraud or tax evasion.

If you have a Swiss financial account or other offshore bank account, the deadline is June 30th for filing an FBAR with the IRS. If you need to make a voluntary disclosure under the IRS Tax Amnesty, contact the tax controversy attorneys at Brager Tax Law Group, A P.C.

Shulman promised to create an inhospitable climate for tax evasion and offshore secrecy by continuing and expanding cooperation with G-20 heads of state, who pledged in unity this April to act against tax havens that impede legitimate tax enforcement. He hopes to enhance information reporting on offshore account holders, increase tax withholding on U.S. citizens with foreign bank accounts in countries deemed "tax havens," double tax penalties for failure to file FBARs, and allow the IRS more time for investigation by increasing the statute of limitations from three years to six years.

The IRS’ effort to eliminate tax fraud and tax evasion is supported by the expansion of President Obama’s 2010 budget. The budget provides funds for increased reporting on cross-border wire transfers, which would allow the IRS to gather information and target individuals who transfer money to and from offshore accounts. Also included is funding for 800 new employees who will deal specifically with international tax enforcement.

In his address to OECD, Commissioner Shulman promised, “If you are a U.S. taxpayer holding overseas assets, you must pay your taxes or we will be very focused on finding you. It’s as simple as that.”

If you have an offshore bank account and have not filed an FBAR, you may wish to consult with a tax attorney at Brager Tax Law Group, A P.C. to understand whether or not you have a tax problem.

The penalty grid imposes a guideline penalty of two to four months for each late filed tax return, even though no tax was due. If the tax return is still not filed at the time OPR contacts the tax preparer then the guideline is four to six months for each non-filed tax return. If the late filings continue for four or more years than the baseline can be doubled! Thus a simple late filing of tax returns for four years can result in a suspension from practice for 32 months even though no tax is due.

If you are CPA, tax lawyer, or enrolled agent who has not filed his tax returns you have a serious tax problem, and you may wish to contact the tax controversy attorneys at Brager Tax Law Group, A P.C.

If you have an offshore tax problem contact the tax controversy lawyers at Brager Tax Law Group, A P.C. to have a consultation which will be covered by the attorney client privilege.

Amodeo collected federal withholding taxes through his numerous payroll tax companies, and then knowingly neglected to forward this tax money to the IRS. Consequently, he was charged and convicted with five felonies: willful tax evasion (totaling $181 million); obstructing an agency proceeding (by intentionally defrauding the IRS in their attempt to collect payroll tax); and conspiring to commit wire fraud, to obstruct an agency investigation, and to impede the IRS. Amodeo was forced to surrender more than $1 million cash, three homes, several luxury automobiles, commercial real estate, a Lear Jet, and his corporations in attempt to fulfill his outstanding tax debt.

While this may have been one of the larger tax fraud cases on record, people have gone to jail for tax evasion for much smaller cases.

If you have any tax problems, including potential tax fraud or payroll tax problems, contact the tax controversy lawyers at Brager Tax Law Group, A P.C.

If your clients have undisclosed offshore accounts, and you wish to discuss their tax problems call the tax controversy attorneys at Brager Tax Law Group, A P.C.

Current law mandates a nonrefundable 20% down payment be submitted with each OIC application. A mandatory non-refundable fee, combined with a very low chance of acceptance (the IRS rejects more than 75% of all OIC applications), makes the OIC program much less alluring to taxpayers who are searching for ways to settle unpaid tax debts. In fact, the number of OICs received by the IRS fell by 21% from 2006 to 2007 when this down payment requirement took effect.

Should Congress pass this pending legislation , the nonrefundable down payment requirement would be repealed. Without this requirement,the OIC would be a much more attractive option to the countless taxpayers who are struggling to settle their tax debts with the IRS.

As our testimonials and success stories demonstrate, our tax attorneys have filed many successful OICs. If you have a tax problem and need a tax lawyer, call the tax attorneys, at Brager Tax Law Group, A P.C.

The terms of the offshore voluntary compliance program as announced left many questions unanswered. Although the FAQs fills in some holes in the offshore tax amnesty program it still leaves gaps. For me the FAQ answers several key questions:

1. How is the 6 year lookback period calculated?

Under the tax amnesty taxpayers are responsible for the 2003 to 2008 tax years.

2. Are “quiet disclosures” acceptable?

No. Taxpayers must make a “noisy disclosure” by contacting the IRS Criminal Investigation Division. Filing amended income tax returns and FBARs is not sufficient.

I will try and post additional information over the next few days.

I would point out, however, that the FBAR FAQs still leaves unanswered the question of whether, under appropriate circumstances, the IRS will negotiate lower FBAR penalties under previously issued FBAR guidelines.

If you have a UBS bank account, or any offshore bank account, and would like further information about the IRS voluntary disclosure program, contact the tax problem attorneys at Brager Tax Law Group, A P.C.

The Reuters revelation is not good news for those with offshore bank accounts who were hoping to keep them secret from the IRS. Even taxpayers who have reported all of the income that was used to fund the offshore accounts are at risk for a 50% FBAR penalty.

We are now reviewing with some of our clients the advisability of taking advantage of the IRS tax amnesty that is available until September 22nd.

If you would like advice on the IRS voluntary disclosure program or any other tax problem contact the tax controversy attorneys at Brager Tax Law Group, A.P.C.

Morgenthau said he was going to Washington to work on expediting the investigations. Although it appears that the New York investigations are centered on money laundering violations by banks and financial institutions, it is probable that evidence will be uncovered relating to individuals with offshore accounts; and such information will be turned over to the IRS, triggering tax fraud and FBAR violation investigations.

Morgenthau's biography highlights that as a U.S. Attorney, he prosecuted tax fraud cases.

If you have an offshore bank account, you should contact a tax litigation attorney to discuss the current IRS "tax amnesty" before the deadline in September passes.

The Internal Revenue Service (IRS) FAQ on FBARs, however, states that this does not include athletes and entertainers who occasionally come to the U.S. to perform.

Whether or not you are a U.S. Citizen or resident, if you have an offshore bank account and have not filed an FBAR, you may wish to consult with a tax attorney to understand whether or not you have a tax problem.

Clients often ask me something like, “How will the IRS know that I have put my funds in a Swiss bank account?” I usually respond, “I don’t know for sure, but what I do know is if they find out you are not going to be happy with what happens next.” Even assuming that the IRS doesn’t get the information directly from the foreign bank this summons is just one example of the IRS obtaining data in ways which might not be immediately apparent to the casual observer.

I have previously blogged about the tax amnesty for holders of offshore accounts. This new lawsuit is yet another reason why those with offshore accounts need to consult with a tax attorney to determine whether or not a voluntary disclosure makes sense.

The Tax Court has requested public comments on the proposed amendments. Written comments must be received by May 27, 2009.

If you have a tax controversy matter which you haven’t been able to resolve contact the tax litigation lawyers at Brager Tax Law Group, A P.C.