Do you have an unreported foreign bank account and you missed the Amnesty Program?

Are you afraid to enter into the I.R.S Voluntary Compliance Program?

You are not alone. Richard Lehman, a Florida tax lawyer, specializing in the amnesty and voluntary compliance areas of tax law is 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.

Lehman believes that a well represented large group of taxpayers is the taxpayers’ best chance of fairness and equal treatment. Learn how to become part of this group contact Richard Lehman Today!

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?

Mr. Lehman has spent years as an attorney with the I.R.S., in addition he has over 35 years of private practice experience representing clients dealing with the I.R.S. Please contact him today to help guide you through the process of determining the best choice available for you, without waiving valuable rights.

Richard S. Lehman, Esq.
2600 N. Military Trail, Suite 270
Boca Raton, FL 33431
561-368-1113 Telephone
561-998-9557 Fascimile

Prior to the announcement of the Amnesty program, the Internal Revenue Service always had a Voluntary Compliance program

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.

Attorney-client privilege is one of the strongest privileges available under law.

Richard S. Lehman, P.A.
2600 N. Military Trail, Suite 270
Boca Raton, Florida 33431
Telephone: (561) 368-1113
Facsimile: (561) 998-9557

Bank Deposit Amnesty New IRS Program gets deadline extended

If you are one of the tens thousands Americans banking overseas in countries like Switzerland and are not paying taxes on income, the United States government is after your identity and is coming fast.

With the U.S. government eagerly seeking the names of all local residents with offshore accounts at the United Bank of Switzerland, they have made a move that might save those who have avoided taxes from any jail time or persecution.

The United States estimates that as many as 50,000 people have offshore accounts with UBS and can take advantage of the new offshore banking amnesty program.

Knowingly not reporting income on your Federal income tax return is a crime and many of the 50,000 with accounts at UBS not paying U.S. taxes could not come forth prior to the government’s new initiative for offshore banking amnesty.

On March 23, the Internal Revenue Service came up with a six-month program giving offshore banking amnesty to U.S. taxpayers with unreported income with UBS or other offshore accounts.

This IRS bank deposit amnesty means any U.S. citizen with an offshore account will get amnesty or freedom from jail or investigations if they come clean, now.

The price for this piece of mind is to pay the income tax, the interest on the income tax and two specific penalties on unreported income and foreign bank accounts for the years 2003 through 2008.

Act Fast, the Clock is Ticking on the Voluntary Disclosure

The offshore banking amnesty program originally terminated on September 23, 2009-- BUT has just recently been extended to October 15, 2009.

Before this offshore banking amnesty, the IRS had another voluntary disclosure policy but one with no guarantees of amnesty and more penalties than the current program.

The current IRS bank deposit amnesty from the IRS DOES guarantee amnesty and has limits on the fines you are liable for.

The IRS bank deposit amnesty or offshore banking amnesty does have requirements.

With the new offshore banking amnesty program, the taxpayer’s voluntary disclosure is sent to the local Criminal Investigation Office that will determine if the disclosure is voluntary, and has been truthful and timely.

The voluntary disclosure under the new offshore banking amnesty requires:

• The formally undisclosed income was not made illegally
• The taxpayer must cooperate to determine what taxes are owed
• The taxpayer must make arrangements to pay past taxes in full and penalties

The most important requirement of the disclosure with the offshore banking amnesty is timing:

• The IRS cannot have initiated any investigation on your income
• The IRS cannot have received information on your noncompliance
• The IRS cannot have gotten information that has to do with your liability from criminal action like a search warrant or grand jury subpoena.

With this new IRS bank deposit amnesty, it is not a good idea to wait to seek help from a tax lawyer.

If you have offshore accounts and feel you qualify for the new offshore banking amnesty, contact a tax lawyer now. There are only months left and the clock is ticking.

Contact Richard Lehman today for a confidential consultation -- 561-368-1113

Richard S. Lehman, P.A.
2600 N. Military Trail, Suite 270
Boca Raton, Florida 33431
Telephone: (561) 368-1113
Facsimile: (561) 998-9557