Every one of our
consulting attorneys,
CPAs & ex IRS Agents
has more than 25 years
of professional
Lance Wallach
FBAR International Taxes

August 2011
Lance Wallach

The FBAR Deadline is here. Filing deadline for the IRS’s offshore tax amnesty (called the Offshore Voluntary Disclosure Initiative). If you don’t properly
comply you will get caught.
For those with current offshore accounts, the deadline to file the annual Report of Foreign Bank and Financial Account (“FBAR”) is here. File your
FBAR Now. The form is known as the
TD F 90-22.1 form. Make sure you check the box on Schedule B of your income tax return that asks if you have
an interest in a foreign account. (Failing to file the FBAR is a felony and so is supplying the wrong information on your income tax return).
* Remember to report any foreign source income too. Thus if you have an offshore savings account make sure you report the interest even if it was
taxed in another country.
Many foreigners living in the U.S. and multiple nations get confused by what gets reported on the U.S. return. The IRS wants to know about all of your
income even if taxed elsewhere. If you don’t have an accountant familiar with
offshore reporting requirements, find one. One missed step could get you
charged with a crime or facing a penalty of 50% of the highest account balance. There are many special rules, and if you don’t use an expert for this
YOU will probably have a big problem. Best to use an ex-IRS agent who had years of experience with the IRS in the international division of the IRS. You’
ll probably need additional advice to what is on the form. There are large fines for mistakes. The FBAR is a Treasury return. You probably need to file
ASAP or at lease contact the IRS with your reason for filing late. They don’t care about the mailing date; it must be received on time. Will they penalize
you if it is received a day late?

Lance Wallach, National Society of Accountants Speaker of the Year and member of the AICPA faculty of teaching professionals, is a frequent speaker
on retirement plans, financial and estate planning, and abusive tax shelters.  He writes about 412(i), 419, and captive insurance plans. He speaks at
more than ten conventions annually, writes for over fifty publications, is quoted regularly in the press and has been featured on television and radio
financial talk shows including NBC, National Pubic Radio’s All Things Considered, and others. 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. Contact him at 516.938.5007, wallachinc@gmail.com or visit
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.

If you have unreported foreign accounts of more than $10,000 and unreported income, you better
come clean with the IRS or you could be in   trouble — the type that can cost you hundreds of
thousands of dollars and even land you in jail.

The willful failure to file the FBAR report or maintain records of your
foreign accounts can potentially lead to a ten-year prison sentence

fines of up to $500,000. This criminal penalty applies to all US citizens
pursuant to 31U.S.C Section S322B and 31 C.F.R. Section 103.S.9.C It may
also apply to persons living in the United States who are not citizens.

If you fail to answer the question truthfully on schedule B of your Form
1040 which asks if you “have an interest in or a signature or other
authority over a financial account in a foreign country”, then your false
statement might be deemed a criminal offense by the IRS per the sections
mentioned above if other surrounding facts and circumstances apply.

If you filed your amnesty request you have now admitted to committing a tax crime. Now the hard part comes. Should you opt out to get a better result?
If you filed your amnesty forms you have now admitted to a criminal offense. What is the best strategy to utilize to deal with the IRS to minimize the
chance for a criminal prosecution? What is the best strategy to deal with the IRS NOW to minimize your fines? YOU need answers now.

Our office is headed by a former international tax IRS agent
with 37 years experience as a CPA and Associate Professor of accounting.
Call our office immediately for a free five-minute consultation so you can
avoid the dire circumstances described above and deal with the other
associated problems.

Has the IRS contacted you to charge you with a crime yet? If not you may have time to do something.
Lance Wallach: For Expertise You Won't Find Anywhere Else
National Office

Please click here to Contact Mr. Wallach.
Additional Resources
Get Him On Your Side:

  • The Millennium Plan
  • SADI Trust
  • The Beta Plan - Hartford -
    PAC Life
  • Compass Welfare Benefit
  • Sea Nine VEBA - Bisys
  • Professional Benefits Trust
  • Advantage - Sterling - Cresp
  • Heritage Plan - Indianpolis
    Life Penmont - and litigation
    invovling other similar 412i
  • Retirement plans
  • 419 Welfare Benefit plans