Wednesday, November 5, 2014

GTi is little but not bad

GTi is little but not bad

Sport mode! Anthony Parent

Thursday, October 23, 2014

Delinquent FBAR filing procedures and Streamlined OVDP FAQs

Delinquent FBAR filing procedures and Streamlined OVDP FAQs For US expatriates who have reported all foreign-sourced income, or did not have any foreign income to report, the IRS has made the delinquent FBAR filing procedures *relatively* straight-forward and *relatively* easy to understand. But here's where things get ugly. This is only true for taxpayers who do not have any unreported income in the last 3 years. Things get complicated in situations where there in no unreported income in the last three years, but unreported income in any one of the three years prior. In this article we will demonstrate the apparent contradictions, and offer strategies for the not-too uncommon issue of having unreported foreign income, not in the last 3 years, but rather, 4-6 years ago. The IRS published Domestic Streamlined OVDP FAQs on October 8, 2014 --- purportedly to clear the air. The IRS is attempting to be intelligent and foresee the questions people will ask. The problem is we only see more confusion. Read more to judge for yourself. Commentary is interspersed with italics, to denote possible future changes, or items of inconsistency. 2014 OVDP Webinar Anthony Parent

Monday, September 15, 2014

FBAR filing instructions -- don't follow the IRM

FBAR filing instructions -- don't follow the IRM

According to the Internal Revenue Service Internal Revenue Manual, Sec (07-01-2008) link here:, "[t]he FBAR is filed by mailing it to the U.S. Department of the Treasury, Post Office Box 32621, Detroit, MI 48232-0621." But this is not true. We have an IRS webpage (linnk here: that says the FBAR "is only available online through the BSA E-Filing System website." (link here: So if the IRS can't get its own FBAR rules straight, what kind of standard of conduct should they impose on you? Anthony Parent

Wednesday, September 3, 2014

Has your OVDP Pre-Clearance or voluntary disclosure been declined or rejected?

Has your OVDP Pre-Clearance or voluntary disclosure been declined or rejected? Was your IRS OVDP or OVDI declined or rejected? If you have produced that which in turn you thought was timely, everything you believed had been complete, Pre-Clearance or Offshore Voluntary Disclosure Plan (OVDP) submission, you can get a letter back from your IRS Criminal Investigation Division informing you which your own voluntary disclosure has been declined regarding not becoming timely and/or complete. In this video, I discuss what should you do in the big event you received this OVDP rejection letter. First thing: A Person must absolutely come together with an attorney for the OVDP. You need a lawyer --- not just a CPA, not an Enrolled Agent, not your better buddy whom usually got anyone out of trouble (unless, involving course, she as well as he is an attorney). Period. If the OVDP was not complete, that's usually an even more straight-forward, but nevertheless difficult, task. It involves receiving with each other all regarding the required documents, neatly organized along with presented inside a method in which benefits a person the most. We've seen way a lot of professionals present disclosures towards the IRS throughout ways inside which benefits the IRS. Therefore many practitioners "mail it in" and cross their particular fingers as well as hope your IRS won't damage their own client too much. Nevertheless guess what? while it holds true which a lengthy time ago, not many IRS agents could view the extremely complexity associated with such items as foreign lifestyle insurance, PFICs, controlled Foreign Corporations and Subpart F income, that's will zero longer true. IRS OVDP Examiners are usually mastering by carrying out and becoming higher level training. They tend to be acquiring much better --- a great deal better. However are getting at representing the particular government! Therefore anyone absolutely have to make positive you do not have a rookie -- whether they're in a big firm or even are solo --- understanding the OVDP ropes along together with your fortune at stake. If your own OVDP had been declined regarding not really being timely If your current OVDP had been declined for not really getting timely you will find a couple of main factors why this could potentially be the case: The IRS already has a civil examination or perhaps criminal investigation one against you The IRS offers notified anyone in which the intends to commence civil examination or criminal investigation The IRS offers received information through a third party alerting the particular IRS for you to your particular non-compliance The IRS provides initiated a civil examination or perhaps criminal investigation of a range of other entity which is directly associated for the specific liability of you, or The IRS has acquired details straight related for the specific liability against from the criminal enforcement action (e.g, search warrant or even grand jury subpoena). So do the thing is how significant this is? Throughout both case --- if your current OVDP or perhaps Pre-Clearance was rejected for not being total as well as timely, for you to protect your current fortune as well as your security, you get to create sure you have an OVDP attorney you are 100% comfortable with. We possess seen a lot of individuals who produced small mistakes along with taxes after which increase the actual danger for larger error of getting low-powered tax help. It is heart-breaking, honestly. people function along with conserve therefore tough to generate wealth upon which they will believed they could rely upon, only to notice their own fortune function as the really factor your IRS uses in order to terrorize these --- people that are just not the biggest criminal masterminds inside the world. If you are confused in what the complete OVDP process is, please watch my 2014 OVDP webinar which is now on replay. Hyperlink here. When you're wondering if we might be the best OVDP firm with regard to you, watch these videos I developed to explain which we have got been not the actual OVDP law firm for everyone, nevertheless then again, might just be the proper firm for you. http:/// Anthony Parent

Wednesday, August 20, 2014

Federal tax evasion: Why it is so easy for the IRS to convict and what you can do about it

Federal tax evasion: Why it is so easy for the IRS to convict and what you can do about it In this video, I explain how the IRS (and Department of Justice) have the upper hand when it comes to tax evasion and other federal tax crimes. If the IRS Criminal Investigation Division investigates you, there is a 90% chance they will seek an indictment. If they seek an indictment, there is a 94% chance the Grand Jury will return an indictment. If they have an indictment, there is a 93% chance that you will plead guilty or be found guilty. There are millions of people the IRS could select for criminal prosecution each year, but the truth is, they can only process about 3000 new criminal cases a year. So the IRS must rule by fear and intimidation with the people the do snare in their nets. Another advantage the IRS has is that jurors and judges tend to favor the government. They can't imagine why anyone would have a problem filing and paying their taxes on time. Jurors and judges tend to look at the IRS as good guys --- the IRS is how judges get paid, and for many jurors, they never, ever had to personally write a check to the IRS. All they get from the IRS is refund checks. And if you rely on professional advice, if you don't understand everything on your tax return, too bad. The law imputes knowledge you could never possess. So how to avoid the trap? Don't be one of the millions of people in current non-compliance with the IRS. Be sure you get into compliance, use a voluntary disclosure program is necessary, get into a collection alternative if you owe the IRS money. And if you are looking for tax savings be aware that if a tax shelter goes bad, the person most likely to testify against you in a criminal case would be the promoters of the tax shelter, whether it is a banker, a CPA or a tax attorney. The line between was is allowable and criminal is razor thin and not always a straight line. So be incredibly cautious. If you do find yourself with in indictment, be aware that to mount the best possible defense, you will be paying hundreds of thousands of dollars, on a lead attorney, local attorney, accountant, and expert witnesses, and support attorneys such as our firm. Unfortunately, just because someone is expensive, does not man they actually have won any trials. Do not be impresses with a name, or an office building or how big a firm is. Whenever interviewing fro your lead attorney, ask them how many trials they have taken to verdict, and how many they have won. NO CRIMINAL ATTORNEY CAN GUARANTEE AN ACQUITTAL. What you defense team can do is all the right things that maximize you chance of acquittal, dismissal or reversal on appeal. Also, having an aggressive tax defense team will maximize your chances of an more favorable plea deal, if necessary. If you are worried about a criminal indictment, or are looking to start assembling your defense team, call our hotline at 888-477-4258 or email Anthony Parent

Tuesday, August 19, 2014

Can I deal with the IRS directly?

Can I deal with the IRS directly? In this video, I describe some of the difficulties the layperson has when dealing with a powerful and confusing IRS. For instance, IRS employees are demoralized. It is difficult to find an employee who is engaged in their job. So details get left out routinely. The IRS has computer systems that aren't integrated. So it is hard for various departments to actually see what is going on. Even the most helpful IRS employee can never represent you. They represent the government. Always. The government looks at you as a tax identification number and a revenue source. That is all. No one at the IRS loses sleep if you lose sleep. Even the Taxpayer Advocate must be an "impartial" advocate. What? How can someone an impartial advocate? Shouldn't your advocate tax your side? The analogy I give is that if you had a brain tumor you would find the best surgeon you could. And if you had a big tax problem you would find the best tax attorney you could. But how do you know if you have a brain tumor or a headache? How do you know if you have a little tax problem or a big one that could destroy your future? The answer is by listening to your gut and getting a professional opinion. Call the IRSMedic IRS problem hotline at 888-477-4258 and get a free evaluation of your tax problem. Or email Copyright 2014 IRSMedic Anthony Parent

Wednesday, July 30, 2014

Did you check "no" on your Schedule B part III line 7a?

Did you check "no" on your Schedule B part III line 7a? Did you check "no" on your Schedule B part III line 7a when the correct answer should have been "yes?" Do NOT freak out. Willful FBAR penalties are not automatic. Willfulness requires more than making a mistake on Schedule B. The IRS agrees: "The mere fact that a person checked the wrong box, or no box, on a Schedule B is not sufficient, by itself, to establish that the FBAR violation was attributable to willful blindness. " In this video I explain why this mistake is so common, and why you need to get a tax lawyer with "Offshore Chops" as recommended by Forbes in this article: To learn more about all of the 2014 OVDP changes, watch my OVDP webinar. Sign up here; #OVDPlawyer #OVDPattorney Anthony Parent