2013 TAX AMNESTY PROGRAMS

Thorn believes there is a strong possibility for a new Amnesty Voluntary Disclosure Program to be initiated by the IRS, based on a public speech issued by IRS representatives.

The IRS is in the midst of introducing a new Amnesty Voluntary Disclosure Program, which should be based on the former disclosure program, originally running from March to October of 2013. The original program helped generate over 15,000 Voluntary Disclosures from U.S. citizens who failed to report taxes from offshore accounts and then produced another 3,000 disclosures after the program’s amnesty time period had expired.

However, on January 21, 2013 the Swiss Federal Administrative Court (the Court) ruled that the Agreement’s “tax fraud and the like” arrangement was too broad and violated the Tax Convention temporarily stopping the SFTA from turning over UBS clients to U.S. authorities. Under the Tax Convention, Swiss banks may be required to provide account information for suspected tax fraud however it does not cover tax evasion.

What the IRS says about Voluntary Disclosure

IRS Commissioner Doug Shulman firmly stands behind the belief that the IRS will begin a new Voluntary Disclosure Program, including the disclaimer, “To be fair to those who came in before the deadline, the penalty and thus the financial cost to participate will increase.”

What Kevin Thorn has to say about Voluntary Disclosure

Kevin E. Thorn, Managing Partner of Thorn Law Group, a law firm that represents many taxpayers throughout the U.S. and around the world with undisclosed offshore accounts, believes “the new Amnesty Voluntary Disclosure Program is a second chance for offshore account-holders who may have missed the first deadline to avoid increased civil penalties and potential criminal prosecution.

This opportunity should not be overlooked by those who have not come into compliance yet.”

What the Taxing Authorities say about Voluntary Disclosure

Taxing authorities strongly support this program due to the generation of new information provided by the disclosures, which may offer the IRS leads to other offshore accounts, based in areas such as Asia and the Middle East; these leads help to extend their investigative focus.
Thorn emphasizes that, “another Amnesty program is a rare opportunity and it should be welcomed.”

Failure to comply with the proper disclosure requirements and filing requirements may lead to audits, substantial financial penalties, and in some cases, criminal prosecution. The U.S. government is committed to bringing all U.S. taxpayers with undisclosed offshore accounts into compliance, one way or another. With the strong potential of a new Voluntary Disclosure Program to be implemented, this is a second opportunity for those U.S. taxpayers who have not already disclosed their foreign bank accounts to come forward and minimize possible criminal liability.

Thorn believes there is a strong possibility for a new Amnesty Voluntary Disclosure Program to be initiated by the IRS, based on a public speech issued by IRS representatives.

The IRS is in the midst of introducing a new Amnesty Voluntary Disclosure Program, which should be based on the former disclosure program, originally running from March to October of 2013. The original program helped generate over 15,000 Voluntary Disclosures from U.S. citizens who failed to report taxes from offshore accounts and then produced another 3,000 disclosures after the program’s amnesty time period had expired.

However, on January 21, 2013 the Swiss Federal Administrative Court (the Court) ruled that the Agreement’s “tax fraud and the like” arrangement was too broad and violated the Tax Convention temporarily stopping the SFTA from turning over UBS clients to U.S. authorities. Under the Tax Convention, Swiss banks may be required to provide account information for suspected tax fraud however it does not cover tax evasion.

What the IRS says about Voluntary Disclosure

IRS Commissioner Doug Shulman firmly stands behind the belief that the IRS will begin a new Voluntary Disclosure Program, including the disclaimer, “To be fair to those who came in before the deadline, the penalty and thus the financial cost to participate will increase.”

What Kevin Thorn has to say about Voluntary Disclosure

Kevin E. Thorn, Managing Partner of Thorn Law Group, a law firm that represents many taxpayers throughout the U.S. and around the world with undisclosed offshore accounts, believes “the new Amnesty Voluntary Disclosure Program is a second chance for offshore account-holders who may have missed the first deadline to avoid increased civil penalties and potential criminal prosecution.

This opportunity should not be overlooked by those who have not come into compliance yet.”

What the Taxing Authorities say about Voluntary Disclosure

Taxing authorities strongly support this program due to the generation of new information provided by the disclosures, which may offer the IRS leads to other offshore accounts, based in areas such as Asia and the Middle East; these leads help to extend their investigative focus.
Thorn emphasizes that, “another Amnesty program is a rare opportunity and it should be welcomed.”

Failure to comply with the proper disclosure requirements and filing requirements may lead to audits, substantial financial penalties, and in some cases, criminal prosecution. The U.S. government is committed to bringing all U.S. taxpayers with undisclosed offshore accounts into compliance, one way or another. With the strong potential of a new Voluntary Disclosure Program to be implemented, this is a second opportunity for those U.S. taxpayers who have not already disclosed their foreign bank accounts to come forward and minimize possible criminal liability.

The Law Offices of Jeffrey B. Kahn, P.C. reminds Americans with undisclosed offshore accounts that they have until August 31 to enter the latest IRS offshore  amnesty program and avoid criminal prosecution and the maximum civil penalties that the law allows. Headed by Jeffrey B. Kahn, the leading tax, probate and business law firm is still accepting clients who need assistance with the IRS program, including filing the application and submitting the complete civil package that includes the amended income tax returns and delinquent FBAR’s.If you need a tax attorney, contact the Law Offices of Jeffrey B. Kahn, P.C. A tax lawyer and one of the best probate attorneys, Kahn offers tax, probate, trust and business law services. Call qualified tax lawyers today.

In a recent press release, Principal Jeffrey B. Kahn had this to say about the IRS deadline:
 ”As sufficient time is needed to prepare the amended tax returns and delinquent FBAR’s, taxpayers who would like to enter the IRS  amnesty program should apply now to insure that the deadline is met and the IRS does not disqualify them from obtaining the benefits of the program.”

Under the 2013 Offshore Voluntary Disclosure Initiative (OVDI) — which was announced in February –  Americans with hidden offshore accounts have until Aug. 31 to report their accounts to the IRS in exchange for a lower penalty and the chance to avoid criminal prosecution.

The penalty structure for the new IRS offshore  amnesty program is higher than that of the previous program, which ended October 15, 2013, but lower than what would ordinarily be paid.

The new initiative requires account holders to pay a fee of 25 percent of the amount in their foreign bank accounts in the year with the highest aggregate account balance over eight years from 2003 through 2013.

According to the law firm, failure to report a foreign account can result in a penalty of the greater of $ 100,000.00 or 50 percent of the amount in the account at the time of the violation. In addition, other criminal penalties including fines and incarceration can be incurred.

If you have not entered the federal  tax amnesty program, now is the time to contact the Law Offices of Jeffrey B. Kahn. The law firm will discuss the benefits and requirements of entering into this program.

Thorn believes there is a strong possibility for a new Amnesty Voluntary Disclosure Program to be initiated by the IRS, based on a public speech issued by IRS representatives.

The IRS is in the midst of introducing a new Amnesty Voluntary Disclosure Program, which should be based on the former disclosure program, originally running from March to October of 2013. The original program helped generate over 15,000 Voluntary Disclosures from U.S. citizens who failed to report taxes from offshore accounts and then produced another 3,000 disclosures after the program’s amnesty time period had expired.

However, on January 21, 2013 the Swiss Federal Administrative Court (the Court) ruled that the Agreement’s “tax fraud and the like” arrangement was too broad and violated the Tax Convention temporarily stopping the SFTA from turning over UBS clients to U.S. authorities. Under the Tax Convention, Swiss banks may be required to provide account information for suspected tax fraud however it does not cover tax evasion.

What the IRS says about Voluntary Disclosure

IRS Commissioner Doug Shulman firmly stands behind the belief that the IRS will begin a new Voluntary Disclosure Program, including the disclaimer, “To be fair to those who came in before the deadline, the penalty and thus the financial cost to participate will increase.”

What Kevin Thorn has to say about Voluntary Disclosure

Kevin E. Thorn, Managing Partner of Thorn Law Group, a law firm that represents many taxpayers throughout the U.S. and around the world with undisclosed offshore accounts, believes “the new Amnesty Voluntary Disclosure Program is a second chance for offshore account-holders who may have missed the first deadline to avoid increased civil penalties and potential criminal prosecution.

This opportunity should not be overlooked by those who have not come into compliance yet.”

What the Taxing Authorities say about Voluntary Disclosure

Taxing authorities strongly support this program due to the generation of new information provided by the disclosures, which may offer the IRS leads to other offshore accounts, based in areas such as Asia and the Middle East; these leads help to extend their investigative focus.
Thorn emphasizes that, “another Amnesty program is a rare opportunity and it should be welcomed.”

Failure to comply with the proper disclosure requirements and filing requirements may lead to audits, substantial financial penalties, and in some cases, criminal prosecution. The U.S. government is committed to bringing all U.S. taxpayers with undisclosed offshore accounts into compliance, one way or another. With the strong potential of a new Voluntary Disclosure Program to be implemented, this is a second opportunity for those U.S. taxpayers who have not already disclosed their foreign bank accounts to come forward and minimize possible criminal liability.

The Law Offices of Jeffrey B. Kahn, P.C. reminds Americans with undisclosed offshore accounts that they have until August 31 to enter the latest IRS offshore  amnesty program and avoid criminal prosecution and the maximum civil penalties that the law allows. Headed by Jeffrey B. Kahn, the leading tax, probate and business law firm is still accepting clients who need assistance with the IRS program, including filing the application and submitting the complete civil package that includes the amended income tax returns and delinquent FBAR’s.If you need a tax attorney, contact the Law Offices of Jeffrey B. Kahn, P.C. A tax lawyer and one of the best probate attorneys, Kahn offers tax, probate, trust and business law services. Call qualified tax lawyers today.

In a recent press release, Principal Jeffrey B. Kahn had this to say about the IRS deadline:
 ”As sufficient time is needed to prepare the amended tax returns and delinquent FBAR’s, taxpayers who would like to enter the IRS  amnesty program should apply now to insure that the deadline is met and the IRS does not disqualify them from obtaining the benefits of the program.”

Under the 2013 Offshore Voluntary Disclosure Initiative (OVDI) — which was announced in February –  Americans with hidden offshore accounts have until Aug. 31 to report their accounts to the IRS in exchange for a lower penalty and the chance to avoid criminal prosecution.

The penalty structure for the new IRS offshore  amnesty program is higher than that of the previous program, which ended October 15, 2013, but lower than what would ordinarily be paid.

The new initiative requires account holders to pay a fee of 25 percent of the amount in their foreign bank accounts in the year with the highest aggregate account balance over eight years from 2003 through 2013.

According to the law firm, failure to report a foreign account can result in a penalty of the greater of $ 100,000.00 or 50 percent of the amount in the account at the time of the violation. In addition, other criminal penalties including fines and incarceration can be incurred.

If you have not entered the federal  tax amnesty program, now is the time to contact the Law Offices of Jeffrey B. Kahn. The law firm will discuss the benefits and requirements of entering into this program.

U.S. citizens and residents are required to pay tax on their worldwide income, even if earned outside the United States. There are also a lot of tax forms that U.S. taxpayers must file, especially when there are international financial activities. The penalties are very large if these forms are not filed on time, or if they are incorrect. Many of these forms do not require any tax to be paid; they just require information to be reported to the IRS.

For people who did not report foreign income, or for people who did not file all of the international tax forms that they should have, the cost for coming clean is very high. If they clean up their past years of tax problems, quite often the taxes, penalties, and interest can be more than the amount of money in their foreign bank account. In a few cases, there is a risk of being sent to prison for tax evasion.

These massive penalties and the threat of prison have for years kept people from coming clean on their offshore tax problems. Recognizing this, the IRS has a temporary program — a voluntary disclosure amnesty program.

The idea is that you come forward voluntarily and disclose everything that you had previously hidden. Pay all of the taxes you owe for the unreported income for 2003 to 2008. Pay 20% of the tax as an additional penalty. Pay interest on the tax and that penalty. Then, pay a penalty based on the highest value of your hidden offshore bank account in the last 6 years. That penalty is either 20% or 5% (if you qualify).

If you qualify for the amnesty program you will be guaranteed these maximum penalties and you will be guaranteed no criminal prosecution.

The deadline for getting your application for the amnesty program started is September 23, 2013.

It is probable that anyone who is discovered after that date with foreign bank accounts and unreported income will face much higher penalties.


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