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Archive for October, 2012

Regal Tax Service and Acme Guitars

Regal Tax Service and Acme Guitars

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$0.00 Down IRS Tax Debt Relief Help For You Now

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William McConnaughy, CPA, Tax Help Pro. IRS and state delinquent tax resolution services: both



Sacramento, USA

Jim Harra

Jim Harra

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Director General of Business Tax

Taxes for Expats Informs Americans Living Abroad About the New IRS Program for Delinquent Tax Filers

US Tax Preparation

New York, NY (PRWEB) September 04, 2012

A new IRS program for delinquent expats and dual citizens is coming into effect on September 1st, 2012. To become compliant, expats will now be required to file three years of tax returns and six years of FBARs.

Why is This Big News?

The new IRS program provides welcome relief for American expatriates who’ve fallen behind on their US tax filing. Unlike past programs, this program makes it clear that by filing now they will not be subject to fines or penalties. Given that most expatriates do not owe any tax and simply did not realize they still have to file US tax returns – this is really welcome news.

Who is Eligible for the New Program?

The new program is aimed at Americans or dual citizens living abroad who have not been filing their US tax returns. But – it is best suited for those who IRS considers ‘low-risk’. The IRS views returns with minimal ($ 1,500) tax due or no tax due to be low risk. After the taxpayer submits their documents, the IRS representative will assess whether the taxpayer can be considered low, moderate, or high risk for compliance. ‘Low Risk’ participants will be free of penalties. The less tax liability, income, assets, and complexity of the return the lower the risk it poses to the IRS. Conversely, the higher the tax liability and the more complex the return will generally lead to a higher assessment of risk.

What About Foreign Retirement Plans?

The new program also will help those with certain foreign retirement plans (such as Canadian Registered Retirement Savings Plans). Existing tax treaties allow such income to be deferred with respect to US tax – but only if such election is made on a timely basis. The new program will allow taxpayers do so even if the election was not made in time.

Is the New Program Better than Previous OVDI & OVDP?

The previous IRS programs had more stringent requirements – filing 8 years of tax returns and 8 years of FBARS. Those entering it also faced the prospect of paying a 27.5% penalty on highest foreign account balance. In contrast, the new program requires only 3 years of tax returns and 6 years of FBARs. Most importantly – its participants may not face any penalties.

Is THIS the time to come clean?

This is a welcome development in what had been a very grey area for US expat tax filers – many of whom wished to be compliant, but had no clear guidance from the IRS itself. IRS Commissioner Doug Shulman said so much himself.

“Today we are announcing a series of common-sense steps to help U.S. citizens abroad get current with their tax obligations and resolve pension issues. The IRS is aware that some US taxpayers living abroad have failed to timely file U.S. federal income tax returns or Reports of Foreign Bank and Financial Accounts (FBARs), Form TD F 90-22.1. Some of these taxpayers have recently become aware of their filing obligations and now seek to come into compliance with the law.”

The program is really good news for Americans abroad who realize that they should become compliant but fear doing so because of potential penalties and fines. Now there is a clear and simple way to achieve compliance endorsed by the IRS itself – without worry about unexpected results.

Should You Go Alone or Hire a Professional?

Even though the new program is really a good news, the taxpayer should tread carefully when dealing with the IRS. One must bear in mind that the primary goal of the IRS is maximization of revenue generated for the US government.

That is why Taxes for Expats recommends that expats contact qualified expat tax professionals to discuss their situation.

If you have any questions regarding the new IRS program or need assistance joining it, Taxes for Expats have a special program. They can help you file last 3 years of tax returns and 6 years of FBARs for a flat fee of $ 1,200 – that’s 27% less than the list price if services were purchased separately. For more information please visit http://www.taxesforexpats.com.

About Taxes for Expats

Taxes for Expats specializes in preparation of US expatriate taxes for Americans and dual citizens living abroad. They offer flat-fee pricing, a simple and hassle-free process, and have over 20 years of experience in the field of expat tax preparation. With clients in over 75 countries around the world, Taxes for Expats have helped hundreds of expats file their back taxes and become compliant with the IRS.


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The General Accounting Office Has A New Report “Information on Foreign-Owned but Essentially U.S.-Based Corporate Groups Is Limited” – GAO -12-743

Washington, D.C. (PRWEB) August 19, 2012

The GAO Report addressed to Senate Finance Committee Chairman Max Baucus (D-MT) and Ranking Member Orrin Hatch (R-UT), can be found at http://www.gao.gov/products/GAO-12-794.

The  new report by the Government Accountability Office (GAO) has analyzed the prevalence of, and potential tax advantages or abuse stemming from, Foreign Controlled Domestic Corporations (FCDC) that conduct the majority of their worldwide operations in the U.S. 

The GAO report, states that a multinational corporate group, whether U.S.-owned or foreign-owned, can generally shift income to subsidiaries in low-tax countries to avoid or evade U.S. taxes, even if the majority of their economic activity is in the U.S. However, use of a FCDC structure can provide a tax avoidance or evasion advantage over structures where U.S. parents own foreign subsidiaries.

The GAO states that FCDC ownership structure could provide a tax avoidance or evasion advantage relative to a structure where U.S. parents own foreign subsidiaries. According to IRS officials contacted by the GAO, the FCDC structure could confer a tax advantage because certain rules that can limit potential abuse by U.S. parent companies and their foreign subsidiaries may not apply to FCDCs and their foreign parent companies. These rules (called anti-deferral rules) make immediately taxable to U.S. corporations certain types of income such as interest, rents, and royalties of their foreign subsidiaries. These types of income tend to be easily moveable from one taxing jurisdiction to another and hence more amenable to transfer pricing abuse. The GAO report also concluded that this structure doesn’t provide a greater opportunity to avoid the transfer pricing rules.

According to tax attorney Alvin Brown, U.S. corporations are generally taxed on income from outside the U.S. just as they are on income from inside the U.S under IRS Code Section 862. This rule is intended to ensure an even playing field and eliminate any tax advantage that would otherwise be derived by a U.S. corporation doing business in a low-tax country. However, subject to certain limitations, the U.S. corporation’s foreign-source income is insulated from U.S. tax until it is actually brought back to the U.S. and distributed to the U.S. owners. Thus, U.S. corporations can defer income by simply forming a wholly-owned subsidiary in a low-tax country. The Code’s subpart F “anti-deferral” regime addresses this issue by taxing U.S. shareholders of a controlled foreign corporation (CFC) on their pro rata share of the CFC’s subpart F income under IRS Code Section 952(a) and investments in U.S. property, regardless of whether these amounts were actually distributed to the shareholders. Under IRS Code Section 482 the IRS is authorized to distribute, apportion, or allocate gross income, deductions, credits or allowances among organizations, trades, or businesses owned or controlled by the same interests in order to prevent tax evasion or to reflect the true taxable income of any such entity. This prevents the shifting of income and deductions among certain related taxpayers for the sole purpose of minimizing taxes. The standard to be applied is that of a taxpayer dealing at arm’s length with an uncontrolled taxpayer. The arm’s length result of a controlled transaction must be determined under the method that provides the most reliable measure of an arm’s length result.

The GAO report concludes that the primary advantage of the FCDC structure is that, unlike U.S. parent companies and their foreign subsidiaries, the anti-deferral rules generally don’t apply to an FCDC structure. Rather, the anti-deferral rules only apply to an FCDC if it is also the owner of a CFC, or to the foreign parent of an FCDC if the foreign parent is itself a CFC.

However, with respect to tax evasion through transfer pricing abuse, FCDC structures don’t provide any particular advantage since they are subject to the same rules as U.S. corporations with foreign subsidiaries. Any questions on this discussion can be addressed to Tax Attorney Alvin S. Brown ab (at) irstaxattorney (dot) com.

The Tax Law Firm of Alvin Brown & Associates

575 Madison Ave., 8th Floor

New York, NY 10022-8511


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