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How Experienced are We?
One of our senior international taxation experts is a former
IRS agent with an MBA degree in Taxation, and he was
employed for 35 years with the IRS as an IRS International
Examiner, an IRS International Team Manager, and an IRS
Appeals Officer. His decades of IRS experience with both
domestic & multinational taxation issues
can help your business today.

Our international experts can help you unlock the tax
codes to help your business maximize the money your
business keeps and to steer clear of the IRS audit and
penalty traps being set now by the IRS doing business in
the USA.

Our experts can assist you with:

* VAT (Value added taxes)
* Transfer Pricing Audits
* Offshore Corporations
* Offshore Tax Shelter issues
* International Taxation
* Multinational Corporations
* 1040 NR
* IC DISC (Interest Charge Domestic International Sales
* Overseas sales tax compliance

If you or your business conducts operations, makes
investments or transacts sales across international borders, it
is imperative you have an international expert consultant to
guide you through the complex laws facing multinational and
domestic companies doing business abroad!

With the recent IRS crackdown on many offshore banks and
insurance companies doing business with US taxpayers, now
not the time to be left out in the cold on your own without
the proper tax advice from our legal experts!

Call the director of today so he can put
you in contact with our international taxation experts.


International Corporate Tax Information You Need to Know
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FBAR International Tax OVDI

Lance Wallach

FBAR and international tax are hot issues that are costing people a lot of money. If you
don’t do it right you will have IRS problems. Be careful who helps you. It may cost you
a lot of money, or in the extreme time in Jail.

U.S. citizens with financial interest or signature authority over any foreign financial
account (including bank, brokerage, securities, or other types of financial accounts)
located outside of the United States, are required to report that information each year.
Since most, if not all, U.S. citizens residing in a foreign country have a foreign bank
account for their ordinary banking activities, they are subject to this same reporting
requirement. If a person is required to file FBARs retroactively, they only have to file
them for the last six years. The statute of limitations for assessing FBAR penalties is six
years from the due date of the FBAR.

A failure to file the FBAR may subject the taxpayer to a willful or a non-willful civil
penalty, in absence of reasonable cause. The civil penalty for willfully failing to file an
FBAR can be up to $100,000 or 50% of the total account balance at the time of the
violation. Non-willful violations are subject to a penalty of up to $10,000 per violation.
However, if the failure to file was due to reasonable cause, as determined by the IRS, then
there is no penalty. Please be very careful how you do this.

The IRS will consider factors such as taxpayer's reliance on a professional tax advisor, no
indication of intent to conceal income or assets and other additional facts that weigh in
favor of a determination that the violation was due to reasonable cause. The IRS will
consider the facts and circumstances of the taxpayer's situation before imposing a penalty
and may instead issue a warning letter. I have received hundreds of phone calls from
people with big IRS problems. Many were caused by them getting bad advise.

The IRS reopened the Offshore Voluntary Disclosure Program (2012 OVDP) with News
Release IR-2012-5 on January 9, 2012. The 2012 OVDP will remain open for an
indefinite period of time, with no set deadline for taxpayers to apply. The overall penalty
structure for the 2012 OVDP requires individuals to pay a penalty of 27.5% of the
highest aggregate balance in foreign accounts/entities or value of foreign assets during the
eight tax years prior to disclosure. Some participants, in limited circumstances, will be
eligible for a lower penalty of 12.5% or 5%.

Taxpayers must consider their specific situation before making a decision about how best
to become compliant with the U.S tax laws. With the announcement of the 2012 OVDP,
they and their advisors need to determine whether they should follow the guidance
provided in IRS Fact Sheet FS-2011-13, file returns for the past six years and hopefully
be granted reasonable cause relief or, alternatively, participate in the 2012 OVDP, file and
pay taxes for the past eight years to obtain amnesty from criminal prosecution. They
should also consider filing and then opting out. If done correctly this may be the best
solution. Consider using an ex ITS agent who was with the international division of the
IRS. If he is a CPA that is even better. I have found you get want you pay for. Do not try
to do this on your own. Do not use a CPA unless he has years of experience on these
issues. You do not want him to learn on the job.

Lance Wallach, National Society of Accountants Speaker of the Year and member of the
American Institute of CPAs faculty of teaching professionals, is a frequent speaker on
retirement plans, financial and estate planning, and abusive tax shelters.  He speaks at
more than ten conventions annually and writes for over fifty publications. Lance has
written numerous books including Protecting Clients from Fraud, Incompetence and
Scams published by John Wiley and Sons, Bisk Education's CPA's Guide to Life
Insurance and Federal Estate and Gift Taxation, as well as AICPA best-selling books,
including Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business
Hot Spots. He does expert witness testimony and has never lost a case. Mr. Wallach may
be reached at 516/938.5007,, or at or www.

The information provided herein is not intended as legal, accounting, financial or any type
of advice for any specific individual or other entity. You should contact an appropriate
professional for any such advice.