I am a Florida tax lawyer, specializing in the amnesty and voluntary compliance areas of tax law, and I am organizing a class of people for the purpose of approaching I.R.S. to force it to apply the “Doctrine of Tax Payer Equality” and extend equal treatment to all taxpayers so that taxpayer(s) can continue to take advantage of long standing policies by the I.R.S. that allow them to clear their records without facing confiscatory civil penalties or criminal violations.
I believe that a well-represented large group of taxpayers is the taxpayers’ best chance of fairness and equal treatment.
If you have an unreported foreign bank account and missed the Amnesty Program -- OR -- If you are you afraid to enter into the I.R.S Voluntary Compliance Program - you should contact my office.
Are you going to wait until more information is supplied to the I.R.S. from foreign banks and face criminal tax charges when you can still avoid them right now?
Sincerely,
Richard S. Lehman, Esq.
2600 N. Military Trail, Suite 270
Boca Raton, FL 33431
561-368-1113 Telephone
561-998-9557 Fascimile
Wednesday, October 28, 2009
Thursday, October 8, 2009
Amnesty – Mostly the Innocent? What do you do about it?
Prior to the announcement of the Amnesty program, the Internal Revenue Service always had a Voluntary Compliance program that would permit taxpayers who had not filed their returns properly, or not filed tax returns at all, to come forward on their own. By voluntarily filing the appropriate tax returns or amended tax returns to make the sure taxpayer was current with the Internal Revenue Service, the criminal tax exposure was waived so long as no investigation of the taxpayer was in process.
This program, which was relied on for years, would normally require the taxpayer to pay the taxes due on the late or amended returns, the interest due on those taxes and a late payment penalty or accuracy penalty of 25%. Other than that, on only rare occasions would a case require the payment of any more penalties, unless of course there was obvious fraud, which could result in higher penalties.
Recently, the Internal Revenue Service published statistics that reflected approximately 3,500 people have taken advantage of the Amnesty Program. This seems rather small in light of the fact that there are published figures that indicate there are approximately 100,000 individuals with offshore bank accounts, approximately 50,000 of which are involved with U.B.S.
From a law practice standpoint, it seems that a lot of the very “innocent” and “near innocent” are stepping forward to take advantage of the Amnesty Program. These are individuals that otherwise would ordinarily qualify for the regular Internal Revenue Service Program.
However, because of the Amnesty Program, the Internal Revenue Service is going to look closer at voluntarily compliance filings “outside” of the Amnesty Program. Therefore, for the first time, taxpayers must face a choice of whether to accept the Amnesty Program with its guaranty of no criminal exposure and its penalty tax of 20% on the bank deposits, or to file under the ordinary Voluntary Compliance Program and avoid criminal exposure, and face potential civil penalties that could be higher than the 20% payment on bank deposits.
In many cases these are taxpayers that have not been hiding bank deposits of unreported income from business or illegal activities. Rather they have been hiding bank deposits from inheritances and other previously taxed income. By choosing amnesty, now everything becomes subject to the 20% bank deposit tax. In accounts where there have been big losses, the removing offshore balances might be less than the 20% tax.
LEARN MORE about this topic from Richard S. Lehman, P.A.
Attorney-client privilege is one of the strongest privileges available under law.
This program, which was relied on for years, would normally require the taxpayer to pay the taxes due on the late or amended returns, the interest due on those taxes and a late payment penalty or accuracy penalty of 25%. Other than that, on only rare occasions would a case require the payment of any more penalties, unless of course there was obvious fraud, which could result in higher penalties.
Recently, the Internal Revenue Service published statistics that reflected approximately 3,500 people have taken advantage of the Amnesty Program. This seems rather small in light of the fact that there are published figures that indicate there are approximately 100,000 individuals with offshore bank accounts, approximately 50,000 of which are involved with U.B.S.
From a law practice standpoint, it seems that a lot of the very “innocent” and “near innocent” are stepping forward to take advantage of the Amnesty Program. These are individuals that otherwise would ordinarily qualify for the regular Internal Revenue Service Program.
However, because of the Amnesty Program, the Internal Revenue Service is going to look closer at voluntarily compliance filings “outside” of the Amnesty Program. Therefore, for the first time, taxpayers must face a choice of whether to accept the Amnesty Program with its guaranty of no criminal exposure and its penalty tax of 20% on the bank deposits, or to file under the ordinary Voluntary Compliance Program and avoid criminal exposure, and face potential civil penalties that could be higher than the 20% payment on bank deposits.
In many cases these are taxpayers that have not been hiding bank deposits of unreported income from business or illegal activities. Rather they have been hiding bank deposits from inheritances and other previously taxed income. By choosing amnesty, now everything becomes subject to the 20% bank deposit tax. In accounts where there have been big losses, the removing offshore balances might be less than the 20% tax.
LEARN MORE about this topic from Richard S. Lehman, P.A.
Attorney-client privilege is one of the strongest privileges available under law.
Tuesday, October 6, 2009
IRS says approximately 3,500 people have taken advantage of the Amnesty Program
Recently, the Internal Revenue Service published statistics that reflected approximately 3,500 people have taken advantage of the Amnesty Program. This seems rather small in light of the fact that there are published figures that indicate there are approximately 100,000 individuals with offshore bank accounts, approximately 50,000 of which are involved with U.B.S.
Monday, October 5, 2009
The IRS extends amnesty deadline for offshore bank accounts to Oct 15, 2009
This IRS Amnesty Program originally terminated on September 23, 2009. IRS recently extended that deadline to Oct 15, 2009.
Now that you may still have time to meet the deadline -- here is a recent article that may help many Americans better understand this IRS Program:
Americans With Foreign Bank Deposits And Unreported Income – A Stay Out Of Jail Card From The I.R.S.
by Richard S. Lehman, P.A.
The most recent headlines include a controversy between the United Bank of Switzerland and the Swiss government versus the Internal Revenue Service of the United States. The U.S. is seeking the names of approximately 50,000 Americans with offshore bank accounts at U.B.S.
The headlines are a result of very strong efforts by the United States in recent years to stop the use of “tax havens” where Americans were depositing unreported income that had not been taxed and were doing so with anonymity and impurity.
Those efforts have started to bear fruit for the U.S. tax collectors. Since knowingly not reporting income on your Federal income tax return is a crime, many U.S. individuals were put in a hard place with important choices to make about taxes.
The Internal Revenue Service has very intelligently made that choice easier.
Read full article: http://www.lehmantaxlaw.com/amnesty_IRS.html
This author has found on many occasions that it is extremely helpful to request that counsel meet directly with the I.R.S. criminal investigator, without discussing the taxpayer’s name, for advice on dealing with gray areas of the law.
Now that you may still have time to meet the deadline -- here is a recent article that may help many Americans better understand this IRS Program:
Americans With Foreign Bank Deposits And Unreported Income – A Stay Out Of Jail Card From The I.R.S.
by Richard S. Lehman, P.A.
The most recent headlines include a controversy between the United Bank of Switzerland and the Swiss government versus the Internal Revenue Service of the United States. The U.S. is seeking the names of approximately 50,000 Americans with offshore bank accounts at U.B.S.
The headlines are a result of very strong efforts by the United States in recent years to stop the use of “tax havens” where Americans were depositing unreported income that had not been taxed and were doing so with anonymity and impurity.
Those efforts have started to bear fruit for the U.S. tax collectors. Since knowingly not reporting income on your Federal income tax return is a crime, many U.S. individuals were put in a hard place with important choices to make about taxes.
The Internal Revenue Service has very intelligently made that choice easier.
Read full article: http://www.lehmantaxlaw.com/amnesty_IRS.html
This author has found on many occasions that it is extremely helpful to request that counsel meet directly with the I.R.S. criminal investigator, without discussing the taxpayer’s name, for advice on dealing with gray areas of the law.
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