Significant Developments Regarding Offshore Accounts, FBARs, FFIs, Form 8938

As of 2016-17, the Offshore Voluntary Disclosure Program (OVDP) has no fixed deadline; however, that may change and a deadline may be imposed by the IRS at any time.

Take advantage of this latest opportunity to nullify dangerous existing criminal exposure by contacting attorney Michael S. Adelman immediately. He will use his more than 46 years as a tax controversy lawyer - 16 as a senior trial attorney with IRS Regional Counsel in Philadelphia - to guide you through the steps of the OVDP process. There is no assurance this opportunity will be afforded again - do this for you and your loved ones' peace of mind.

  • United States citizens living abroad and dual citizens: The IRS has provided an opportunity in certain circumstances for you to become fully compliant despite previous intentional or inadvertent failures to comply with tax reporting requirements as to foreign financial accounts. The recently issued regulations concerning this procedure should be legally evaluated in conjunction with the Offshore Voluntary Disclosure Program (OVDP). It is important that dual citizens contact Mr. Adelman to see if you qualify for a streamlined OVDP procedure.
  • In tax year 2013, Foreign Account Tax Compliance Act (FATCA) requirements began for both foreign banks and individuals. This will greatly increase the possibility that in the future, the IRS will become aware of any nonreporting issues.

Contact Mr. Adelman to evaluate which aspects of the federal tax amnesty opportunities might best fit your circumstances. Long-distance, including international, consultations, with extremely competitive, step-at-a-time legal fees, can be structured.

All communications to your attorney are confidential and guided by attorney/client privilege. This privilege does not apply to communications with accountants, enrolled agents and most nonlegally staffed tax resolution companies. Carefully "vet" such advertising-heavy companies.

  • IRS collection, filing and payment delinquency cases: The IRS has issued many FRESH START opportunities and expedited procedural options to give people a chance to "dig out." One or more of these options may be available to you, no matter how many years of unpaid taxes are involved, even for those already the subject of frightening enforced collection action (notices, tax liens, wage attachments, bank levies, etc.).
  • Even if you have not filed tax returns (including Individual Income Tax Forms 1040 and/or Employment Tax Forms 941 and 940) for many years, Mr. Adelman will work with you and an Accountant will work with you to help you get into compliance. With experienced guidanced this is fixable.

Whether or not you have received notices or have been otherwise contacted by the IRS, please call Mr. Adelman. He will help you through the process of becoming fully compliant, taking steps to resolve all delinquent filings and unpaid tax periods and getting up to date under one of the Fresh Start options or via other avenues if you do not fit the criteria for the IRS' Fresh Start initiative. What may seem to be an insurmountable problem that grows worse every year is absolutely solvable working as a team guided by Mr. Adelman's decades of tax controversy experience.

  • The fairly recent developments discussed in this website article are each based on the IRS' understanding that thousands of people, many already with significant criminal and/or civil federal tax exposure, really want to become compliant, but simply do not know where to begin or how to navigate what often are complex IRS procedures and requirements.
  • The IRS is inviting such people to trust that if certain leaps of faith are made, a fair resolution will be achieved through a win-win process. A "kinder, gentler" IRS? Not entirely, because there is hard work to be done to qualify for these programs and opportunities, and in most cases there will be a financial (tax) price based on your documented circumstances. At the end of this process, virtually all of my clients assure me that the peace of mind was absolutely worth it.

The next step is up to you. Contact Mr. Adelman online or by phone at 856-330-4035 to begin.