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Thursday, September 17th, 2009
As the IRS Amnesty Period is drawing quickly to its expiration date next Wednesday, September 23rd, 2009, overseas account holders must act quickly to voluntarily disclose their funds abroad to reduce their chances of criminal prosecution.
Over Labor Day weekend, a member of the wealthy and privileged elite, Finn M. W. Caspersen, took his own life in the Shelter Harbor Golf Club in Rhode Island. Authorities believed that Caspersen may have owed up to $100 million in back taxes and IRS penalties, and may have even faced prison time.
Whether Caspersen really owed the government that much money or not is not clear, but it is unfortunate when someone chooses to end their life over IRS tax problems. IRS debt can seem overwhelming and can sometimes seem like the end of the world–I’d like to remind you that for every IRS tax problem, there is a IRS tax solution. You are entitled to professional tax help–don’t let your tax problems cripple your financial future.
According to the NYTimes.com, “The I.R.S. learned that Mr. Caspersen held an account at LGT, the private bank controlled with Liechtenstein’s royal family. Liechtenstein pledged last December to disclose the names of some wealthy Americans with bank accounts there, but it was unclear if Mr. Caspersen’s name was among them or how the I.R.S. learned of any account in his name. According to the person familiar with the investigation, federal authorities recently placed tax liens on the personal trusts of Mr. Caspersen’s four sons.”
The latest IRS crackdown on the use of offshore bank accounts by wealthy Americans led to the UBS deal where the big Swiss bank divulged the names of nearly 300 of its American clients in February and agreed to hand over several thousand more last month.
For those who owe back taxes on their money abroad, it’s important to act now before the Amnesty Period ends next Wednesday. By partaking in voluntary disclosure, you will pay a significantly less amount of IRS penalties than what you will owe if you wait to be caught. For instance, if you have one million dollars offshore – that will equal to about $400,000 in IRS penalties in interest. If you don’t do the voluntary disclosure the penalties jump to 2.3 million on a $1 million asset. Additionally, not voluntarily disclosing your foreign bank account will expose you to possibly severe criminal charges. (If you participate in voluntary disclosure before September 23rd, your chances for criminal prosecution will be greatly reduced.)
It is unwise to take your chances of not getting caught by sitting this wave out, voluntary disclosure is a good way for those who owe back taxes for their foreign bank accounts to seek IRS penalty relief. Act now before the September 23rd deadline to save your financial future before it’s too late!
Tax Resolution Services works with clients on voluntary disclosures – so if you owe back taxes or interest/penalties on offshore accounts, we can help. Don’t wait for IRS to come after you, we can help you resolve your IRS problems before it’s too late. Can contact our team of experts for a free consultation. Call us at 866-IRS-PROBLEMS (1-866-477-7762) or visit our website at www.TaxResolution.com
Tags: Back Taxes, delinquent tax returns, delinquent taxes, failure to file, FBAR, Finn M. W. Caspersen, Free Tax Consultation, IRS debt, irs problems, Michael Rozbruch, overseas bank account holders, tax attorney, tax evasion, tax expert, tax help, tax resolution, UBS deal
Posted in Back Taxes, Tax news and tips, tax help | 1 Comment »
Tuesday, August 25th, 2009
It’s official–UBS, the Swiss Banking Giant has reached a deal with the US Government and the Swiss Government to release around 4,450 names of American account holders suspected of tax evasion.
The US Government estimates there to be $18 billion hidden in these offshore accounts–giving the IRS plenty reason to scrutinize and audit both the innocent and guilty in the upcoming months.
If you have a UBS account and have not paid your taxes, you can still decrease the severity of your charges by participating in voluntary disclosure. Currently, the IRS offers an Amnesty Program for tax evaders who come forward before their names are disclosed by UBS. (The deadline for this program is September 23rd, 2009).
If you come forward to the IRS before UBS does, the IRS will drop all criminal charges in exchange of you paying all back taxes plus penalties and interest. Considering this exchange could make the difference between jail time and an affordable payment plan, it is worthwhile for tax evaders who have significant unpaid taxes.
Taxpayers are required by law to disclose all income from domestic and foreign sources–all of which are taxable. Therefore, if you are going through an IRS audit or have found yourself in trouble with the IRS, it is best to get professional tax help from an experienced tax attorney, CPA, or certified tax resolution specialist.
Guilty or innocent, it’s crucial for taxpayers with offshore bank accounts to be prepared for severe IRS scrutiny. Get professional tax help now before it’s too late. In most cases, finding the most qualified tax lawyer or tax resolution specialist can significantly reduce your IRS penalties.
Read more on how you can pick the best tax attorney to help you fight the IRS.
Tax Resolution Services is the only national tax resolution firm certified by the ASTPS to negotiate tax settlements with the IRS. We are a nationwide professional tax solution company with a team of tax attorneys and IRS specialists who can help you find tax relief. Free tax consultation – sign up on our website or call us at 866-IRS-PROBLEMS (866-477-7762).
Tags: amnesty period, IRS help, Michael Rozbruch, Penalty Abatement, tax attorney, tax attorneys, tax debt, tax evasion, tax evder, tax expert, tax help, tax lawyer, tax relief, tax resolution, tax resolution expert, tax resolution services, UBS tax settlement, Voluntary Disclosure
Posted in IRS Question Corner, Penalty Abatement, Seeking Professional Tax Help, Tax news and tips, Voluntary Disclosure | 1 Comment »
Monday, August 24th, 2009
Hope everyone had a great weekend! CNBC.com reporter Mark Koba quoted me in a recent article about last week’s agreement by Swiss bank UBS to name US account holders. This is being seen as a watershed, leaving many wealthy Americans with foreign accounts scrambling to figure out what to do
Anyone who has not checked the Report of Foreign Bank and Financial Accounts (FBAR) box on Schedule B of form 1040 and/or has deposited monies into these foreign accounts without paying federal income taxes (earned income) on them should be nervous about being targeted by the IRS in their crackdown on foreign accounts.
However, people in this situation can still strike a deal with the IRS in exchange for full voluntary disclosure. We do this all the time for our clients – we go straight to the IRS instead of the IRS seeking out our client. The voluntary disclosure program offers immediate relief because the IRS agrees not to criminally prosecute taxpayers who pay all back taxes plus interest and penalties. But in order to take advantage of this immediate relief, taxpayers must come forward before their names are turned over to the IRS.
And remember that a tax attorney or tax resolution specialist can help you resolve IRS tax problems if your offshore account comes under scrutiny by the IRS. Contact us today for a free tax relief consultation to see if you qualify for a voluntary disclosure settlement.
Tags: Back Taxes, IRS debt, IRS help, IRS tax problems, mark koba, Michael Rozbruch, offshort accounts, overseas bank account, Report of Foreign Bank and Financial Accounts (FBAR), swiss bank UBS, tax attorney, tax evasion, tax expert, tax settlement, Voluntary Disclosure
Posted in Seeking Professional Tax Help, Tax news and tips, Voluntary Disclosure, Working with the IRS | No Comments »
Friday, August 21st, 2009
As Swiss bank UBS and the Swiss government consider reneging on a deal to turn over 52,000 names of U.S. clients, Justice Department warns criminal prosecution may be next step
By Michael Rozbruch
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For those who follow tax compliance news, February was a big month.
That’s when the U.S. Department of Justice announced a deal with Swiss bank UBS.
The U.S. government agreed to waive criminal prosecution — federal prosecutors suspected the Swiss bank helped American clients evade as much as $300 million a year in taxes from 2002 to 2007 — if UBS would provide the U.S. government with the names of its 52,000 U.S. clients.
The government, of course, suspects these 52,000 U.S. clients are using their Swiss bank account to hide money and avoid income taxes. For wealthy Americans, that’s been a well-laid plan, since Swiss banks are known to offer absolute privacy.
Until now. Well, maybe.
Following the unprecedented agreement, the Swiss have hemmed and hawed, saying an order to release client names would violate Swiss banking law.
A Miami judge asked federal prosecutors what they would do if UBS reneged on the deal. Their response: UBS bank officials would face criminal prosecution.
This is quickly becoming something of an international banking incident. But what does it means for you, an American taxpayer?
A lot, in fact.
Take what John A. DiCicco, Acting Assistant Attorney General for the Justice Department’s Tax Division, said earlier this year about obtaining UBS’s records: “It is time for those who are trying to hide from the IRS to rethink their actions. The Department of Justice is committed to do all that it can to aid the IRS in locating those who would seek to hide behind secret accounts and in holding them accountable under the federal tax laws.”
What DiCicco means, it’s safe to say, is this: The IRS has now mustered its entire strength to dismantle the mechanisms that in the past have facilitated tax evasion.
The highest profile of these mechanisms are Swiss banks, which have made fortunes over the last century operating with a success model that promised to protect money without asking questions or telling secrets. From Americans trying to hide money to dictators trying to steal it, Swiss banks offered the best option.
So to combat tax evasion, the IRS has targeted everything from credit cards to banks located overseas, and in the past year, the federal government has been remarkably successful at obtaining records, creating a sort of tip sheet of those who may be cheating Uncle Sam.
For American taxpayers such as you, the writing is on the wall: Time is short. That’s because, if you’ve used a traditional method of evading taxes such as overseas banks, the IRS will soon find out, if it hasn’t already.
Uncle Sam won’t back down from tax cheats. Ask the secretive Swiss.
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If your offshore account comes under scrutiny from the IRS and you need tax help, Tax Resolution Services can advise you on how to avoid IRS problems. They can also help you with the voluntary disclosure process and filing any back taxes (delinquent taxes) that need to be taken care of.
Michael Rozbruch is a Certified Tax Resolution Specialist, a member of the American Society of IRS Problem Solvers and a Maryland CPA. You can contact him at 866-IRS-PROBLEMS (866-477-7762) to obtain a free subscription to his newsletter titled The IRS Times & Inquirer or read stories from the newsletter on our blog.
Tags: cheating Uncle Sam, delinquent taxes, Department of Justice deal with UBS, failure to pay income tax, filing back taxes, irs problems, John A. DiCicco, Michael Rozbruch, Offshore Banking, Overseas Banking, swiss bank, Swiss banking, tax attorney, tax cheat, tax evasion, tax resolution, tax shelter, tax specialist, UBS, unfiled returns, Voluntary Disclosure
Posted in Back Taxes, IRS Tax Cases, IRS Times and Inquirer, Unfiled Returns - Delinquent Tax Returns, Voluntary Disclosure, Working with the IRS | No Comments »
Thursday, August 13th, 2009
UBS and the U.S. and Swiss governments are nearing a settlement over the Swiss bank’s forced disclosure of 52,000 names of U.S. clients suspected of tax evasion.
While the final form of agreement is not yet in place, there are many implications for U.S. taxpayers, including innocent offshore account holders who did not use their Swiss accounts to evade taxes. They may be heavily investigated, so it will be important for them to know their rights and seek a tax attorney’s representation when necessary.
Details of the UBS agreement may also affect the pace of activity under an IRS amnesty program that lets Americans reveal secret Swiss bank accounts in exchange for lower penalties. Through the program, taxpayers with unreported income in foreign bank accounts van avoid criminal prosecution and lower IRS penalties in exchange for voluntary disclosure of their foreign account and payment of all back taxes plus interest.
Taxpayers are required to report all income from domestic and foreign sources. I recently blogged about requirements for offshore account holders to file a Report of Foreign Bank and Financial Accounts (FBAR), which cannot be filed with federal tax returns. The deadline to file with the Department of the Treasury in Detroit, Michigan has been extended from June 30, 2009 to September 23, 2009. While there may be some confusion about who is required to file an FBAR, the IRS is providing extra time for taxpayers to seek tax help.
Remember that a tax attorney or tax resolution specialist can help you avoid IRS problems if your offshore account comes under scrutiny by the IRS. You can contact us for a free consultation to see if you qualify for a voluntary disclosure settlement.
According to Reuters, the days of secret bank accounts are numbered for Americans.
The deal is also expected to put European tax dodgers on notice as other governments are encouraged to seek out hidden accounts.
U.S. authorities believe the 52,000 U.S.-based clients of UBS may be hiding nearly $15 billion of assets.
For more IRS news and tax help tips, follow me on Twitter @taxresolution
Tags: delinquent taxes, Foreign Bank and Financial Accounts (FBAR), IRS help, irs problems, offshore accounts, offshort bank accounts, tax attorney, tax cheats, tax debt, tax evasion, tax expert, tax help, tax relief, tax resolution, tax resolution services, Tax Resolution Specialist, UBS settlement, Voluntary Disclosure
Posted in Back Taxes, Tax news and tips, Voluntary Disclosure, Working with the IRS | 3 Comments »
Friday, July 31st, 2009
UBS has just struck a deal with the US Government to give up 52,000 names of Americans who have Swiss bank accounts. In the upcoming weeks, we can expect to see many guilty tax evaders being charged with heavy IRS penalties as well as innocent account holders who will need to defend themselves. (Read more about the latest UBS settlement.)
It is not uncommon for American businesspeople to hold foreign bank accounts, especially if their business is international. Due to the recent heavier IRS enforcement, it is extremely crucial for you to understand everything you are required (by law) to do if you have a foreign bank account or if you have signatory authority over an offshore account. Failure to comply with IRS regulations regarding FBAR will result in severe tax penalties that could debilitate your financial well-being for life.
Currently, taxpayers are required to report all income from domestic and foreign sources. In addition, taxpayers who have a financial interest in or signature authority over foreign accounts are required to file a Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR), if the aggregate value of all such financial accounts exceeds $10,000 at any time during the calendar year. The FBAR cannot be filed with your federal tax return. Instead, it is filed with the Department of the Treasury in Detroit, Michigan no later than June 30 of the year following the calendar year reported. There is no extension of time available for filing this report.
Failure to report income in foreign bank accounts, or to file Form TD F 90-22.1, has serious consequences; there are civil and criminal penalties, and both can be imposed in appropriate cases. However, until September 23, 2009, taxpayers with unreported income in foreign bank accounts have an opportunity to take advantage of an IRS settlement offer. In exchange for full disclosure, the IRS agrees not to criminally prosecute those taxpayers not already under investigation who pay all back taxes plus interest and penalties. In addition, the IRS waives the 75 percent fraud penalty for taxpayers who voluntarily disclose their foreign accounts.
If your offshore account has come under scrutiny by the IRS and you’re not sure if you qualify for a voluntary disclosure settlement, consult a professional tax specialist.
If you find yourself in trouble with the IRS but have a reasonable cause for your neglect or ignorance of the IRS rules, you have a chance at winning yourself a penalty abatement.
Oftentimes, people find themselves in trouble with the IRS because they do not realize their inaction (in certain situations) was illegal. Do not be one of the innocent people who has to pay heavy tax penalties for ignorance. Educate yourself and stay informed.
99% of the time, Tax Resolution Services will keep an IRS tax case in the civil arena and out of the criminal arena, if you find yourself in IRS tax trouble, you can contact our team of experts for a free consultation. Call us at 866-IRS-PROBLEMS (1-866-477-7762) or visit our website at www.TaxResolution.com
Source: Stuart A. Goodman for CCH, July 31, 2009
Tags: delinquent taxes, FBAR, foreign bank account compliance, IRS audits, IRS enforcement, IRS help, irs problems, Michael Rozbruch, offshore accounts, tax audit, tax audits, tax cheat, tax cheats, tax evasion, tax fraud, tax help, Tax Tips, UBS tax settlement, Voluntary Disclosure
Posted in Penalty Abatement, Seeking Professional Tax Help, Taxpayer Rights, Voluntary Disclosure | 2 Comments »
Tuesday, July 28th, 2009
Recently I spoke with Russ and Sully on the Big Biz Show to discuss how the more aggressive IRS tax collection effort is affecting tax cheaters as well as innocent law-abiding taxpayers.
Unfortunately, during this tense climate of increasing IRS enforcements, even some innocent people are going to get weaved into the mix and may find themselves in IRS trouble. Many of these innocent taxpayers will be able to explain and prove their innocence. It is always a good idea to understand the procedures of filing a case against the IRS to maximize chances of success. You are entitled to the help of a professional tax attorney–make sure you choose the right one for you.
Read on for some of the pertinent questions during today’s tax environment:
Q: For those people with bank accounts in Switzerland or have used the Bahamas as a tax haven, what can we expect now with the Obama Administration going after offshore accounts so aggressively?
A: We’re going to see the end to the secretive banking laws. The US Government has already sued the Swiss Government for the 52,000 names on the Swiss bank accounts. It is very probable that the Swiss is going to give those names up because the press has been announcing that the Swiss wants to cooperate. And if that happens, there’s going to be a lot of unhappy people in this country with regard to that. These tax evaders will have to answer to their crimes here and face the appropriate IRS penalties.
Q: What will happen to someone who inherits money from someone that recently passed away and is unaware of the tax responsibility they have on the inheritance?
A: Many people do not know that the money they inherit from someone–be it a 401k or an IRA–is taxable to the beneficiary. There could be hundreds of thousands of dollars in the retirement fund that was tax-free during the life of the person but when they pass, that money is all of the sudden taxable. If you inherit money and do not pay taxes on it, you are committing tax evasion and will be punished as that.
Q: If someone finds themselves in trouble with the IRS for failing to file for taxes in the past couple of years, what will you do to help them?
A: The first thing Tax Resolution Services does is we make a Voluntary Disclosure to the IRS—in other words, we’re going to the IRS instead of the IRS seeking out our client. One phone call from Tax Resolution Services can help you keep the case civil. 99% of the time, we keep the cases civil even when the IRS has already been contacting you to file those back taxes.
Voluntary Disclosure offers immediate relief for a couple of reasons: Number One, the client doesn’t have to talk or deal with the IRS from that point forward. We take over all correspondence and communications; Number 2, it keeps the case in the civil arena because it is a misdemeanor punishable by one year in prison to not file a return when it’s due. So we keep the case out of the judicial arena and keep it civil.
Listen to the full interview for more tax tips!
Avoid harsh IRS tax penalties. If you find yourself at odds with the IRS but are innocent of the charges, you are entitled to seek a professional tax attorney’s representation.
Don’t fight the IRS alone–you can contact our team of experts for a free consultation. Call us at 866-IRS-PROBLEMS (1-866-477-7762) or visit our website at www.TaxResolution.com
Tags: IRS audits, IRS debt, IRS enforcement, IRS help, IRS problem solver, tax audit, tax cheats, tax debt, tax evasion, Tax Tips
Posted in Tax news and tips, tax help | No Comments »
Wednesday, July 1st, 2009
Swiss banks are shutting the accounts of Americans as the Internal Revenue Service accelerates the hunt for tax dodgers. The country’s biggest banks, UBS AG and Credit Suisse Group AG, have told Americans to move their money into specially created units registered in the U.S., or lose their accounts. Smaller private banks such as Geneva-based Mirabaud & Cie. are closing all accounts held by U.S. taxpayers.
After the American government’s legal battle to get UBS to disclose the owners’ names for 52,000 accounts in which Americans evaded taxes – the IRS announced a new Voluntary Disclosure process that offers leniency to taxpayers with unreported income relating to offshore transactions. Along with lower tax penalties, those who come forward, pay their taxes, and comply with the IRS are expected to avoid criminal prosecution.
Until now, the IRS could impose penalties of at least 50% for all years in which an account wasn’t disclosed. In some cases, that could exceed the value of the offshore holdings. But voluntary disclosure isn’t about how much you end up paying, it’s about being able to avoid jail time.
While the IRS has since increased pressure on Americans to disclose offshore accounts, Swiss banks must comply with U.S. tax rules and register with the Securities and Exchange Commission to accept a investment from a U.S. person.
According to Bloomberg:
While the banks declined to say how many people are affected, more than 5 million Americans live abroad, including about 30,000 in Switzerland, according to estimates from American Citizens Abroad in Geneva. Swiss banks must register with the Securities and Exchange Commission to provide services for those customers.
SEC registration means clients don’t enjoy the protection of Swiss banking secrecy laws, which make it a crime for money managers to disclose the names of clients without their consent. Switzerland said in March it would cooperate with international tax evasion probes after Zurich-based UBS admitted helping U.S. clients avoid taxes.
The IRS has since increased pressure on Americans to disclose offshore accounts as it seeks to recoup an estimated $50 billion in unpaid taxes. The agency set a deadline of Sept. 23 for taxpayers to declare all foreign accounts or face possible criminal prosecution that could result in as much as 10 years in prison and $500,000 in penalties.
Presumption of Guilt
U.S. citizens must file tax returns, report offshore accounts that contain more than $10,000 and pay tax on any income earned, no matter where they live. To take advantage of the amnesty program, taxpayers must file six years of returns, plus pay back taxes and a penalty, according to the IRS.
If you owe the IRS more than you can afford to pay, get help from the specialized staff of tax attorneys, CPAs, EAs and tax professionals at TRS. Visit Tax Resolution Services for a free income tax relief consultation or call us at 866-IRS-PROBLEMS (1-866-477-7762).
Tags: avoiding IRS penalties, Back Taxes, delinquent tax returns, IRS penalties, irs problems, IRS tax problems, Michael Rozbruch, offshort accounts, Swiss bank accounts, tax cheats, tax dodgers, tax evasion, tax expert, tax help, tax relief, tax resolution, tax resolution expert, tax resolution services, Voluntary Disclosure
Posted in Tax news and tips | 4 Comments »
Monday, June 29th, 2009
In an effort to bring more tax evaders to the surface, the IRS has issued a new voluntary offshore compliance initiative in March of 2009, which provides more lenient penalties for tax evaders who have placed their assets overseas. In this initiative, taxpayers who voluntarily disclose their wrongdoings will only be punished with paying back taxes, certain penalties, and interest. Those who come forward will not face criminal charges unless strong evidence suggests criminal behavior. Since this compliance initiative overlooks the criminal prosecution aspect of tax evasion, it is useful for anyone who has wrongfully concealed their full income in past tax returns.
Also, the FBAR (Report of Foreign Bank and Financial Accounts) filing deadline has been extended from June 30, 2009 to September 23, 2009. Due to the newly changed definition of “United States person”, there has been confusion over who is required to file the FBAR; those who are filing for the June 30th deadline should use the July 2000 definition of “United States person” instead of the newly changed definition.
CCH (http://tax.cchgroup.com/) reports:
The IRS is combing amended returns for taxpayers who have made “quiet disclosures” to circumvent the Service’s temporary offshore compliance initiative. The Service reiterated in new frequently asked questions (FAQs) about the initiative on its website (www.irs.gov) that taxpayers who make quiet disclosures will not escape penalties and possible criminal prosecution. The Service also is giving some taxpayers additional time to file Form 90-22.1, Report of Foreign Bank and Financial Accounts (known as the “FBAR”).
Quiet Disclosures
The IRS launched its voluntary offshore compliance initiative in March (TAXDAY, 2009/03/27, I.3). In exchange for full disclosure of offshore accounts and the payment of back taxes, interest and certain penalties, the IRS will not seek criminal prosecution of wrongdoers. In April, IRS Commissioner Douglas H. Shulman said he was pleased with the response but the Service has been tight-lipped about how many taxpayers have come forward.
Rather than formally applying to participate in the initiative, some taxpayers have filed amended returns reporting previously undisclosed assets. The IRS is reviewing amended returns. The Service cautioned that, if it discovers evidence of criminal behavior, it will recommend criminal prosecution.
Taxpayers whose quiet disclosure returns have not been selected for examination may request to participate in the initiative. These taxpayers must meet all of the criteria for participation, the IRS explained.
FBARs
June 30, 2009, is the deadline for filing 2008 FBARs. The IRS previously clarified the filing requirement for FBARs (IR-2009-58, Announcement 2009-51; TAXDAY, 2009/06/08, I.5). A recent change in the definition of “United States person” created confusion for filers. For FBARs due on June 30, 2009, taxpayers should use the prior (July 2000) definition to determine who must file an FBAR, the IRS explained.
Now, the Service has provided additional FBAR relief. Taxpayers who recently learned that they have an FBAR filing obligation but do not have sufficient time to gather the necessary information to file by June 30 may file before September 23, 2009, without penalty. The taxpayer must have reported and paid tax on his or her 2008 taxable income, the IRS cautioned. This treatment mirrors similar relief previously provided to tax years before 2008.
“The September 23 deadline is good news,” Walter Goldberg, IRS Practice & Procedures, executive director, Grant Thornton, LLP, Washington, D.C., told CCH. “Taxpayers and practitioners are hopeful that the IRS will continue to answer questions about the initiative.”
By George L. Yaksick, Jr., CCH News Staff
Tags: Back Taxes, FBAR, interest, IRS debt, irs news, penalties, quiet disclosures, tax audit, tax deadline, tax help, tax problems, tax resolution, voluntary offshore compliance initiative
Posted in IRS Overview, Penalty Abatement, Tax Debt Help News, Tax Relief News, Tax news and tips, tax help | No Comments »
Thursday, May 14th, 2009
The IRS has announced a six-month Voluntary Disclosure program that offers lower penalties to those who come forward and pay taxes due on the secret holdings in offshore accounts. Until now, the IRS could impose penalties of at least 50% for all years in which an account wasn’t disclosed. In some cases, that could exceed the value of the offshore holdings.
The announcement comes amid a U.S. legal battle to get owners’ names for 52,000 UBS accounts in which Americans evaded taxes by holing at least $14.8 billion in Swiss banks.
The IRS also issued a list of 30 frequently asked questions about the Voluntary Disclosure process – which offers leniency to taxpayers with unreported income relating to offshore transactions. Along with lower tax penalties, those who comply are expected to avoid criminal prosecution
We have been making one disclosure after another – including some “quiet disclosures.” While the IRS encourages taxpayer to come forward under the voluntary disclosure offer, it is also possible to file amended returns and pay any related taxes and interest for previously unreported offshore income without otherwise notifying the IRS.
Quiet disclosures should only be attempted by specialized and experienced tax experts, as any amended tax returns reporting increases in income run the risk increased scrutiny from the IRS.
Income tax relief under the voluntary disclosure process is open to all taxpayers that comply with IRS’s terms, including corporations, partnerships and trusts, as well as those taxpayers that have an offshore merchant account. The offer does not apply if IRS has initiated a civil examination of the taxpayer, regardless of whether it relates to undisclosed foreign accounts or undisclosed foreign entities.
According to USA Today:
Under the plan, owners who disclose foreign accounts would pay:
* Back taxes and interest for a minimum of six years.
* A 25% delinquency penalty for each year in which tax returns weren’t filed, or a 20% accuracy penalty for years in which returns were filed but income from offshore accounts wasn’t included.
* A penalty equal to 20% of the highest aggregate value at any point during the last six years for all previously secret foreign accounts.
Robert McKenzie, a lawyer for more than a dozen American clients with UBS accounts, predicted the program would prompt more disclosures because it would enable evaders to compute their liability “almost to the penny” — which wasn’t possible before. The IRS said the number of Americans who have disclosed foreign accounts has more than doubled this federal fiscal year over 2007-08.
** If you require assistance with a voluntary disclosure or need help resolving other IRS problems, contact our specialized staff of tax attorneys, CPAs, EAs and tax professionals. Visit the Tax Resolution Services web site for a free income tax relief consultation or call us at 866-IRS-PROBLEMS.
Tags: amending tax returns, back tax, filing tax returns, income tax relief, IRS help, IRS penalties, irs problems, IRS tax problems, Michael Rozbruch, off shore banking, quiet disclosures, tax attorney, tax evasion, tax expert, tax resolution, tax resolution services, UBS legal battle, Voluntary Disclosure
Posted in Tax news and tips, Voluntary Disclosure | 1 Comment »
Monday, March 30th, 2009
In a blow to tax cheats, Switzerland’s largest bank agrees to divulge the names of those suspect of using offshore accounts to evade U.S. taxes
By Michael Rozbruch
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In the world of tax cheats, the news doesn’t get much bigger.
UBS, the largest bank in Switzerland, agreed to provide to the U.S. government with the names of those it suspects of using its accounts to evade paying taxes in the United States. The unprecedented move comes after UBS agreed to pay $780 million to settle an investigation of its activities.
Federal prosecutors suspected UBS helped American clients evade as much as $300 million a year in taxes from 2002 to 2007.
How many names of wealthy American tax cheats UBS will provide in this newest measure is unclear. However, according to a lawsuit the Department of Justice filed against UBS in Miami, as many as 52,000 U.S. customers hid their UBS accounts from the government in violation of tax laws.
According to a UBS document filed with that Miami lawsuit, as of the mid-2000s, those secret accounts held about $14.8 billion in assets.
“At a time when millions of Americans are losing their jobs, their homes and their health care, it is appalling that more than 50,000 of the wealthiest among us have actively sought to evade their civic and legal duty to pay taxes,” said John A. DiCicco, Acting Assistant Attorney General for the Justice Department’s Tax Division, in a statement at the time of the lawsuit’s filing.
“It is time for those who are trying to hide from the IRS to rethink their actions. The Department of Justice is committed to do all that it can to aid the IRS in locating those who would seek to hide behind secret accounts and in holding them accountable under the federal tax laws.”
For those using offshore accounts to evade taxes, this should be among the final warnings that they are not safe. Even the wealthiest of tax cheats, the ones using the Swiss banks whose records many considered impenetrable by the U.S. government, are now at risk of total exposure and prosecution by the IRS and the Department of Justice.
While the news is certainly surprising, it isn’t shocking.
For several years, the IRS has been moving more and more aggressively toward tax cheats who use offshore accounts to hide their assets. Many tax cheats once used offshore accounts linked to credit cards that then were employed to purchase goods and services in the United States — seemingly a way of keeping money off the IRS’s books.
That, of course, stopped working once the IRS forced MasterCard to turn over records of those customers whose cards were linked to offshore accounts.
At this point, now that the largest Swiss bank is cooperating with the federal government, there are no safe havens for tax cheats. It’s time to turn yourself in.
“Taxpayers should talk to a tax professional and come forward under our voluntary disclosure process,” said IRS Commissioner Doug Shulman. “Having the IRS find you could mean a much heavier price than coming forward on your own.”
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Michael Rozbruch is a Certified Tax Resolution Specialist, a member of the American Society of IRS Problem Solvers and a Maryland CPA. You can contact him at 866-477-7762 to obtain a free subscription to his newsletter titled The IRS Times & Inquirer. If you are having tax problems, contact us for a free consultation with one of our tax attorneys and IRS problem solvers!
Tags: doug shulman, Free Tax Consultation, John DiCicco, offshore accounts, offshore tax evasion, Swiss bank accounts, Swiss banking, tax cheats, tax evasion, tax problems, UBS
Posted in IRS Tax Cases, IRS Times and Inquirer | 1 Comment »
Friday, March 27th, 2009
The IRS announced new voluntary disclosure practices for offshore account holders. Voluntary disclosure can help taxpayers avoid prosecution for possible tax evasion and reduce taxes, penalties, and interest owed. The IRS offers leniency for voluntary disclosure and Americans with IRS tax problems should take advantage of this policy to mitigate legal problems later.
While taxpayers can participate in the voluntary disclosure program before the IRS has initiated a civil or criminal examination or before the taxpayer has received notice of such an investigation, it remains unclear as to whether those charged with offshore tax evasion and concealing back accounts in Switzerland may successfully participate in this initiative.
CCH (http://tax.cchgroup.com/) reports:
The IRS has announced new steps to coax U.S. taxpayers with undisclosed foreign bank accounts to come forward. In return for paying back taxes for the past six years, plus interest and a set of stiff penalties, the IRS will promise not to bring criminal charges or the 75-percent fraud penalty. IRS Commissioner Douglas H. Shulman announced this policy shift and clarification at a press briefing from his Washington, D.C. offices on March 26, at which he also released internal IRS documents that put the plan into motion.
“We believe the guidance represents a firm, but fair, resolution of these cases and will provide consistent treatment for taxpayers,” Shulman explained. “The goal is to have a predictable set of outcomes to encourage people to come forward and take advantage of our voluntary disclosure practice while they still can.” He set a deadline of six months for disclosures under the terms of the guidance, at which time the program will be re-evaluated.
The IRS has issued a series of three memoranda, and has revised the Internal Revenue Manual (IRM), to reflect updated policies concerning voluntary disclosure, primarily in connection with offshore transactions. Voluntary disclosure occurs when a taxpayer timely discloses information necessary to determine or correct the taxpayer’s liability. The IRM continues to provide that its voluntary disclosure practices do not create any substantive or procedural rights for taxpayers, but are a matter of internal IRS practice.
Voluntary Disclosure Terms
Shulman emphasized that the terms being offered for the disclosure of offshore accounts are an outgrowth of current policy and carry penalties at a level consistent with voluntary disclosure programs in the past. Within this framework, Shulman enumerated the amounts that would need to be paid by taxpayers with heretofore undisclosed offshore accounts who “come clean” under the program:
- Back taxes due on newly disclosed assets for the last six years;
- Interest due on these back taxes for the last six years;
- A 20-percent accuracy-related under Code Sec. 6662 or a 25-percent delinquency penalty under Code Sec. 6651 for each tax year at issue; and
Looking to the past six years, a 20-percent penalty on the total balance of all the taxpayer’s foreign bank accounts or assets during the year among the past six in which the accounts had their highest aggregate value.
While Shulman observed that the penalties demanded under the program are not insubstantial, he pointed to several advantages to participating taxpayers regarding what the IRS will not do:
- The IRS will not pursue charges of criminal tax evasion against taxpayers who voluntarily disclose their offshore assets under this new policy; and
- The IRS will not pursue other penalties against participating taxpayers, such as the Code Sec. 6663 fraud penalties (75-percent of the unpaid tax) or the statutory penalty for willful failure to file a TD F 90-22.1, Report of Foreign Bank and Financial Accounts Report, (FBAR) (the greater of $100,000 or 50-percent of the foreign account balance) that both annually apply to undisclosed accounts and assets during the relevant tax years.
Shulman also touted the advantage to offshore account holders of “getting the matter behind them” and giving them certainty as to their tax liability.
In a follow-up comment, an IRS spokesman emphasized that “it is too late for any taxpayer who is under criminal investigation to make a voluntary disclosure. The IRS cannot discuss specific situations, but the voluntary disclosure process does not apply when the IRS has information related to a specific taxpayer from a criminal enforcement action.”
By Torie Cole and Sherri Morris, CCH News Staff
Follow me onTwitter @taxresolution
Tags: avoid IRS penalties, Douglas Shulman, Michael Rozbruch, offshore accounts, offshore tax evasion, reduce IRS penalties, tax evasion, tax expert, tax help, tax relief, tax resolution, tax resolution expert, tax resolution services, tax settlement, tax shelter, Voluntary Disclosure
Posted in Tax news and tips, Voluntary Disclosure | 2 Comments »
Wednesday, January 14th, 2009
President-elect Barack Obama called Timothy Geithner’s tax problems an “embarrassment,” but also referred to the situation as an “innocent mistake.” So don’t expect Geithner’s $34,000 tax bill to disqualify him from the new administration’s Treasury Secretary appointment.
According to reports, Geithner failed to pay self-employment taxes for money he earned from 2001 to 2004 while working for the International Monetary Fund.
News reports state that the amount that Geithner paid was $16,000 for the audit in 2006 and another $26,000 in a voluntary disclosure. (Voluntary disclosure can help mitigate legal problems later. The IRS offers leniency for voluntary disclosure and it is good advice for any American with IRS tax problems to take advantage of this policy).
It’s interesting to note that Geithner’s voluntary disclosure and payment occurred just days before he was nominated for Treasury Secretary. While the amounts owed and paid are not terribly large, the broader issue being raised by some senators is that this position oversees the IRS.
And what kind of a signal will this send to thousands of IRS employees as well as taxpayers?
The Associated Press reported:
It was the unpaid taxes, though, that were proving more damaging. Obama’s team says his mistake was a common one for people hired by international organizations and foreign embassies that don’t pay the employer share of Social Security taxes. The IRS estimated in 2006 that as many as half those employees had made tax-filing mistakes, and offered a group settlement to let them correct the errors.
But the Finance Committee, in 30 pages of documents released on Tuesday, noted that the IMF issues several clear guidelines each year for its employees detailing their responsibility to pay all their self-employment taxes, and that Geithner had signed annual statements saying that he would do so. He also had experience dealing with such taxes, the panel noted.
Tags: geithner, Michael Rozbruch, tax expert, tax help, tax problems, Treasury secretary, Voluntary Disclosure
Posted in Tax news and tips | 2 Comments »
Tuesday, November 25th, 2008
The IRS has is reportedly going after the relatives of Holocaust survivors and refugees who hid money in Switzerland before World War II broke out.
Reports out of Zurich indicate the Swiss government has agreed to give the IRS information about some overseas accounts for people trying to avoid U.S. banking laws. The development stems from a U.S. Justice Department investigation of UBS’ alleged courting of wealthy Americans for such offshore tax evasion. As the Justice Department expands its investigation to include other overseas banking entities, some owners of Holocaust-era accounts have sought legal help in “coming clean” with the IRS.
Among the 20,000 or so accounts currently being targeted by the IRS, it’s estimated, perhaps a thousand or so involve Holocaust-era funds. The amounts in the accounts range from as little as $25,000 to complete hidden fortunes in the millions.
The clients of the Swiss banks are being advised that that voluntary disclosure can help mitigate legal problems later. The IRS offers leniency for voluntary disclosure and it is good advice for any American with IRS tax problems to take advantage of this policy.
A timely disclosure of a substantial unreported tax liability shows that the taxpayer is willing to cooperate with the IRS in determining his or her correct tax liability. This is an important factor in deciding whether the taxpayer’s case should ultimately be referred for criminal prosecution.
Tags: offshore tax evasion, tax evasion, tax expert, vountary disclosure
Posted in Tax news and tips, Voluntary Disclosure | No Comments »
Friday, January 4th, 2008
Abatement A partial or complete cancellation of taxes, penalties or interest owed by a taxpayer.
ACS See Automated Collection System.
Automated collection System (ACS) A computerized collection process for IRS collectors to contact delinquent taxpayers by telephone and mail.
Collateral Agreement An agreement sometimes secured by the IRS prior to acceptance of an Offer in Compromise when the IRS wants to cover a future, reasonably possible event, such as a significant increase in income.
Collection Division Tax collectors who work out of the IRS Service Center, Automated Collection or District Office.
Collection Information Statement (IRS Forms 433-A, 433-B, and 433-F) IRS financial statements which require disclosure of personal information, particularly assets, income and expenses.
Correspondence Audit A correspondence audit is done by mail. The IRS sends you a letter either alleging you forgot some item of income or requests to see the documentation to substantiate a deduction you have taken on your tax return. The most common type is the CP2000 notice, a computer generated notice that you failed to report an item of income. These must be checked closely since the reporting agency, often time the Social Security Administration for W2’s, can make typographical errors. If you fail to properly dispute these errors the IRS is free to assess and collect the tax they believe is owed. And if ignored long enough, your only recourse is to pay the tax, penalty, and interest and then sue the IRS in court, an expensive proposition.
Current Market Value The amount you could reasonably expect to be paid for the asset if you sold it today. You can find out the value from realtors, used car dealers, publications, furniture dealers, or other experts on specific types of assets. You are advised to include o copy of any written estimate with your Collection Information Statement.
Delinquent Return A tax return not filed by the due date (April 15) or by the dates allowed through the IRS extension periods (August 15 and October 15).
Examination Official IRS term for an audit.
Expenses Not Generally Allowed Expenses not allowed such as claim tuition for private schools, public or private college expenses, charitable contributions, voluntary retirement contributions, payments on unsecured debts such as credit card bills, cable television charges and other similar expenses as necessary living expenses. These expenses can be allowed when you can prove that they are necessary for the health and welfare of you or your family or for the production of income.
Fair Market Value The price a willing buyer and seller of property would agree on as fair; neither being under any compulsion to buy or sell and both having reasonable knowledge of relevant facts.
Federally Authorized Only Enrolled Agents, CPA’s and Attorneys are allowed to represent taxpayers before the IRS. An unenrolled tax preparer can defend a client for whom he prepared a tax return during audit but cannot take it to appeals or represent the taxpayer before the collections division. Our members are all federally authorized to represent all taxpayers. We are not affiliated with nor are employees of the IRS. We work exclusively to provide you with the best representation possible in your controversies with the IRS.
Field & Office Audits Audits are an examination of the tax return you filed with the IRS. The examiner, typically a Revenue Agent, looks for undocumented income and unsubstantiated expenses or deductions. If the audit is performed in the IRS office, it is considered an office audit. These are common for wage earners. If the audit is conducted at the taxpayer’s home or place of business, these are field audits. For our clients, field audits are typically conducted in our offices. It is generally too disruptive to have an IRS auditor or examiner hanging around your office for several days.
Freedom of Information Act A federal law giving citizens the right to see governmental documents, including their IRS files.
Future Income The amount the IRS could collect from your future income by subtracting necessary living expenses from your monthly income over a set number of months. For a cash offer, you must offer what you could pay in monthly payments over forty-eight months (or the remainder of the ten-year statutory period for collection, whichever is less). For a short-term deferred offer, you must offer what you could pay in monthly payments over sixty months (or the remainder of the statutory period for collection, whichever is less). For a deferred payment offer, you must offer what you could pay in monthly payments during the remaining time we could legally receive payments.
Garnishments Garnishments are ongoing levies. Most common is the wage garnishment in which the IRS takes all but a pittance of your take home pay. The IRS would serve its garnishment on your employer. The employer is required to leave you a preset amount to live on (although you couldn’t live on the amount the IRS authorizes) and send the balance to the IRS toward your tax debt. The garnishment is one of the most effective tools the IRS has to get you to the bargaining table. And most employers hate garnishments since it creates a lot of extra work for their payroll department. Some employers have policies against having unresolved tax debts. We have a strong track record of getting the IRS to release the garnishment.
Installment Agreement The installment agreement is a payment plan between you and the IRS. The IRS has some flexibility regarding the payment amount as long as the debt will be paid off before the statute of limitations expire. If the amount due is small and you are offering large payments, it can be quite simple to get an installment agreement. The agreement comes with some strings attached, such as staying current on the filing and paying of future tax returns for as long as the agreement is in place. Penalties and interest will continue to be charged although the penalty rate is currently reduced during the installment agreement. The IRS charges a nominal fee to setup an installment agreement. For larger debts or those debts involving payroll tax issues the IRS may elect to assign a Revenue Officer (debt collector) to determine the maximum payment they can bet from you.
Jeopardy Assessment An expedited procedure by which the IRS imposes a tax liability without notifying you first. A jeopardy assessment is rare and used when the IRS believes the taxpayer is about to leave the country or hide assets.
Levies A levy is the taking of an asset. Most common is the bank levy. The IRS serves a levy notice on your bank for money held in your account. The account is frozen for an amount of money up to the amount owed to the IRS. If there is less in the account than you owe, the whole account is frozen for 21 days. During that time the original amount in the account is locked up. Any new money added is not part of the original levy. At the end of the 21 days the money is transferred to the IRS unless you have obtained a release from the IRS. Most levies are one-shot deals but the IRS can continue to get new levies on a daily basis. They generally don’t. Part of resolving tax debts is to obtain from the IRS a release of the levy.
Liens A lien is merely a statement alleging that you owe a tax debt. It is legally created anytime you owe taxes. It can show up on your credit report, and if the IRS locates property you own, it can be filed against the property. The most common example is a lien filed against your home. Once filed, you cannot sell the asset until the lien is paid off. For houses, the payoff is part of closing. And if you don’t have sufficient equity to payoff the mortgage(s) and lien, you can only sell your home by bringing your own money to closing.
Liquidation Value The amount the IRS can get from a distress sale of a taxpayer’s assets, usually a public auction (typically 70% of fair market value).
National Standards Allowances for food, clothing and other items, known as the National Standards, apply nationwide except for Alaska and Hawaii, which have their own tables. Taxpayers are allowed the total National Standards amount for their family size and income level, without questioning amounts actually spent.
Necessary Expenses The allowable payments you make to support you and your family’s health and welfare and/or the production of income. This expense allowance does not apply to business entities. Publication 1854, How to Prepare a Collection Information Statement (Form 433-A), explains the National Standard Expenses and gives the allowable amounts. We derive these amounts from the Bureau of Labor Statistics (BLS) Consumer Expenditure Survey. We also use information from the Bureau of the Census to determine local expenses for housing, utilities, and transportation. Note:If the IRS determines that the facts and circumstances of your situation indicate that using the scheduled allowance of necessary expenses is inadequate, we will allow you an adequate means for providing basic living expenses. However, you must provide documentation that supports a determination that using national and local expense standards leaves you an inadequate means of providing for basic living expenses.
Notice of Deficiency An IRS notice informing a taxpayer that he or she owes the IRS the amount listed, which is the excess of the taxpayer’s correct tax liability for the taxable year over the amount of taxes already paid for such year.
Offer in Compromise (OIC) The “pennies on the dollar” program allows taxpayers to settle their tax debt for something less than full payment. The criteria is fairly rigid and was designed by Congress, not the IRS. It is a pure business decision. The IRS determines what it could liquidate you for and adds to that what it could collect over the next 48 months and arrives at a minimum amount it might accept. The OIC program is a great program for those that qualify. But don’t use it lightly since it stops the running of the statute of limitations on collections. Proper preparation of IRS financial statements is the key to a good OIC. And since the IRS is back-logged with Offers, patience is a virtue. But for those that qualify, this is a great program. Offers can be made with a lump sum payment or payments over time (much like an installment agreement). Acceptance by the IRS of an offer does come with strings attached, such as staying current with filing and paying for five years after the offer is accepted.
Penalties The IRS assesses two types of penalties on late filed income tax returns. The first and most expensive is the failure to file. Any tax return filed after the due date, including extensions, is considered late. The penalty is based upon the balance due with the tax return. The second penalty is the failure to pay. This is also based upon the amount due with the tax return and is calculated from the due date of the return, without regard to extensions. Some people erroneously believe that since they have a refund they don’t need to worry about filing on time. However, if the return is ever audited and the result is a balance due, the penalties will be based upon the due date of the return, even if the audit occurs 2 years later.
Pending, offer An offer pending starting with the date an authorized IRS official signs Form 656 and accepts your waiver of the statutory period of limitation, and remains pending until an authorized IRS official accepts, rejects or acknowledges withdrawal of the offer in writing.
Petition A form filed with the US . Tax Court requesting a hearing to contest a proposed IRS tax assessment.
Power of Attorney (IRS Form 2848) A form appointing a tax representative to deal with the IRS on your behalf
Protracted Installment Agreement An installment agreement that extends beyond the period allowed under IRS issued guidelines.
Quick Sale Value The amount that can be realized from the sale of a taxpayer’s assets when financial and other pressures force the taxpayer to sell quickly—typically in ninety days or less. This amount generally is less than current value, but may be equal to or higher, based on local circumstances—typically 80% of fair market value.
Realizable Value The quick sale value amount minus what you owe to a secured creditor. The creditor must have priority over a filed Notice of Federal Tax Lien before we allow a subtraction from the asset’s value.
Reasonable Cause There are a variety of reasons why taxpayers don’t file or pay. Divorce, job loss, death of family members, mental or physical diseases, drug and alcohol problems, dog ate the homework, etc. are many of the reasons why taxpayers fail to file or pay. The law allows for the abatement (removal) of penalties for reasonable cause. Obviously, it is very subjective.
Reasonable Collection Potential (RCP) The total realizable value of your assets plus your future income. The total is generally your minimum offer amount.
Reconsideration Audit reconsiderations are discretionary on the part of the IRS. However, we have been successful in convincing the IRS to reopen an audit where the taxpayers were poorly represented or new information is now available that was not available at the original audit.
Local Standards Maximum allowances for housing and utilities known as Local Standards, vary by location. Unlike the National Standards, taxpayers are allowed the amount actually spent, or the standard, whichever is less. There are separate allowance amounts for transportation expenses.
Running Out The IRS has 10 years to collect on back taxes unless the time period has been extended, either by consent of the taxpayer or by certain actions of the taxpayer. The most common reason for the statute of limitations to collect to have been extended is when the IRS has no ability to collect on the debt. Typically, this is because the taxpayer was out of the country, had made an Offer in Compromise, or was under the bankruptcy court. During the time the IRS could not legally collect the running of the 10-year statute of limitations is stopped (tolled). Knowing what has happened during the 10 years is critical to knowing when the IRS can no longer dun you for the debt. It is not uncommon for a tax debt to be removed because the time to collect has expired. The IRS is allowed to accept payments from you but they can’t dun you for any debt that is outside the statute of limitations for collections.
Statute of Limitation Legal limits imposed on the IRS for assessing and collecting taxes, and on the Justice Department for charging taxpayers with tax crimes. The current statute of limitation for collection is 10 years from the date of assessment. However, the statute can be extended by certain actions of the taxpayer.
Substitute for Return (SFR) The law allows the IRS to take the income reported to it under your social security number and file a tax return for you. If you were single the prior year, they will file you as single. If you were married the prior year, they will file a return for you as married filing separate. They will not take any itemized deductions you might be legible for nor will they deduct for any dependents you might be entitled for. It will be a very basic return designed to produce the highest amount of tax allowed to the IRS. It is rarely in your best interest. And since you didn’t file the return yourself, the year remains open (subject to assessment and collection) forever.
Taxpayer Advocate Service An IRS program that provides an independent system to assure that unresolved problems are promptly and fairly handled.
Trust Fund Recovery Penalty (formerly called 100-percent Penalty) A penalty incurred by the responsible person(s) of a business for failure to pay Withholding and Federal Insurance Contributions Act Taxes (Social Security taxes)
Uncollectible A temporary designation by the IRS meaning a taxpayer does not have significant assets or available income, at the present time, from which to satisfy an IRS debt in part or in full. This designation takes a case out of collection, until a taxpayer has an ability to pay.
Waiver Voluntarily surrendering a legal right, such as the right to have the IRS collection period on a delinquent tax debt expire at the end of the statutory time period. The IRS may require waivers in exchange.
Tags: collateral agreement, current market value, currently not collectible, delinquent return, future income, IRS penalties, Jeopardy Assessment, levies, Liens, liquidation value, Notice of Deficiency, Offer in Compromise, Penalty Abatement, Statute of Limitation, wage garnishment
Posted in Delayed IRS Collection and Currently Not Collectible St, Freedom of Information Requests, Offers in Compromise, Penalty Abatement, Statutes of Limitations – Taxpayer’s rights, Tax Help Definitions, Tax Liens and Levies, Taxpayer Advocate | 2 Comments »
