Sales tax audits are one of the areas of practice that I am most proud of at our firm. We have dealt with some very difficult cases and gotten some really phenomenal results. I credit that to the hard work and diligence of our team. Brotman Law really understands sales tax audits.
Brotman Law
Tax Return Demand from the FTB Intensifies
{{cta(’09b64408-9310-4451-9a41-0234b45d370e’,’justifyright’)}}Are you a marketplace facilitator or out-of-state business who has received a tax return demand from the California Franchise Tax Board? If so, read this before you respond. We’ve provided the essential background information you need to formulate a plan prior to your response.
How to File Delinquent International Tax Returns
If you are not in need of the Streamlined Procedures because you do not owe additional tax, and you have reasonable cause for not filing an informational return, you may file the delinquent information returns along with an explanation of the facts that support your claim of having reasonable cause for failing to file on time. You must do this before a civil examination or criminal investigation has been opened.
What Is the Offshore Voluntary Disclosure Program?
Previously, the IRS had two programs, Offshore Voluntary Disclosure Program (2009) and Offshore Voluntary Disclosure Initiative (2011), which have been discontinued. In their place, the IRS has implemented a new program “affectionately” known as Son of OVDP, but is still known as OVDP.
How to Appeal an FBAR Penalty
If you cannot come to an agreement in resolving the issue in the IRS examination stage, you still have a right to take your case to Appeals. As mentioned above however, it may currently be in your best interest to work with the IRS agent and not depend on the case to go your way in Appeals.
FBAR Penalties: What Happens If You Don’t File International Taxes
An area of difficulty that has arisen with regard to FBAR cases is the ambiguity of penalties potentially faced by an individual in violation of disclosure requirements.
Types of International Tax Forms
There are many informational forms associated with international taxes and I am not sugar-coating this — they are complicated. To add to the angst, failure to file these forms or not file them on time can incur hefty penalties. In a later chapter, we will discuss the various compliance programs you may be eligible to participate in. I like to lay out all of the scenarios regarding penalties to my clients up front, so they know what we are potentially dealing with.
What Is the Foreign Bank Account Reporting
The acronym FBAR stands for Foreign Bank Account Report and refers to a disclosure form that must be filled out by certain taxpayers with respect to financial accounts maintained abroad. Although this is often a concern for the millions of expatriates living and working in foreign countries, FBAR applies to an even broader demographic of taxpayers.
Frequently Asked Questions About IRS Collections and Taxes
In my years of representing clients before the IRS, I have been asked some common questions about the IRS, filing taxes and collections. The following is a compilation of my responses to some of the questions I hear the most from my clients. I hope that this Q&A section answers some of the questions that you may have. As always, if you have additional questions, please feel free to call me and I will do my best to answer them for you.
What Is the FAST Act?
The IRS means business when it comes to recouping what is owed to them. Their latest strategy is implementation of the FAST Act. Simply put, if you owe more than $50,000 to the IRS, the IRS can seize your passport, thus prohibiting your ability to travel outside the U.S. This can be particularly problematic if you frequently travel overseas or have a residence in another country.