The US Tax Code and, the myriad of supporting primary authority, are an extremely complex and dense collection of laws. Outside of a California tax attorney and other experienced tax professionals, few laypeople understand the full extent of the tax laws contained within the code or the potential consequences of noncompliance. Many people seem to believe that good-faith efforts at tax compliance will satisfy the IRS, but the fact is that even honest mistakes can lead to significant fines, penalties and even the possibility of referral for criminal tax prosecution. And if you think that time alone will resolve your tax problems, think again. The IRS can typically open an investigation within three years of a filing. In instances of where the government can establish willful non-compliance, the statute of limitations extends for back to the dawn of time. If you have failed to file, your tax liability is equally theoretically open-ended.
If you believe that you or your business has tax compliance issues or tax concerns you should address them immediately with the assistance of an experienced California tax attorney and CPA, such as David W. Klasing. For more than 20 years David W. Klasing has assisted clients throughout California and the world with their domestic and international tax concerns and issues.
California Tax Attorneys handle foreign tax issues
The Banking Secrecy Act (BSA), Foreign Account Tax Compliance Act (FATCA) and intergovernmental agreements (IGAs) between the United States and more than 100 foreign jurisdictions are only a few of the legal reasons as to why tax havens are no longer safe from detection. Aside from the enabling legislation, the Internal Revenue Service has also stepped-up efforts to identify those with undisclosed foreign accounts and to enforce tax fines and penalties. An experienced California tax attorney will attest, that under the jurisdiction of the IRS are required to disclose foreign financial accounts in which they have an interest in or hold signature authority over if the balance in one account or if the aggregate balance in all accounts exceeded $10,000 at any point during the tax year.
Penalties for undisclosed foreign financial accounts can be extremely harsh. A non-willful violation of your disclosure obligations can result in a fine of $10,000 per unreported account, per tax year. A willful violation is subject to a penalty of the greater of $100,000 or 50% of the account value to be imposed per tax year where the account went unreported (with a 5 year FBAR statute a 250% penalty is theoretically possible). If the IRS detects other violations of the tax code, additional penalties may apply. In some situations where it appears criminal wrongdoing may have occurred, your matter may be referred to the Internal Revenue Service Criminal Investigation Division.
California Tax Audit Representation
If you have been selected for a tax audit randomly or because the numbers that you provided to the IRS did not add up, you could face serious consequences. Even a routine, random audit can potentially uncover unreported income, unfiled taxes, unpaid taxes or other serious tax problems. Working with an experienced tax professional can provide peace of mind and decrease the likelihood that your California tax audit will result in serious tax consequences. If we do identify a problem in your returns, foreign account disclosures or in other tax obligations, as Tax Attorneys and CPAs, we are trained and experienced in advocating and negotiating on behalf of taxpayers.
Tax Attorneys can Explain Your Options for Tax Relief and Restitution
Depending on you particularized situation, it is conceivable that a tax audit could result in a tax bill for significant amounts of unpaid taxes. This unpaid tax bill may be further inflated by significant penalties, fines and interest. For many with an unpaid tax obligation, the shock of a large tax bill can make the situation seem impossible or insurmountable. However, the situation may not be as dire as it appears to a tax layperson. In many instances, an experienced California tax attorney can develop a strategy so that you can achieve full compliance while minimizing the consequences of making the disclosures that allow you to come back into compliance.
In some instances our attorneys may recommend a written appeal in response to unacceptable California tax audit results. To appeal you must file a written notification of your intent to appeal and identify the determination or determinations you disagree with, the legal basis for your claim, the factual basis for your claim, and any other relevant information.
Once a determination of tax liability is made on terms that are hopefully beneficial to the taxpayer following and audit, our attorneys can also make what is known as an offer-in- compromise to the state of California and the IRS. An offer-in-compromise can constitute a single lump-sum payment, a payment plan for less than what was originally owed, or both. In other instances, where a single spouse is responsible for the tax debt, filing for injured spouse relief may be appropriate. Many other for tax relief measures are also available to our attorneys. Working with an experienced tax professional can help you understand your full range of legal options and each option’s likelihood of success.
Put our Tax Experience to Work for You in California
To schedule a reduced-rate initial consultation about your California or Federal tax issues with an experienced tax professional, contact the Tax Law Offices of David W. Klasing online or call (800) 681-1295