Monday, March 3, 2014

Statute of Limitations Remains Open Forever for Any Return Which Fails to File an Associated Information Report!




Taxpayer spend some of their time monitoring when the statute of limitations expires for certain tax return exposure items. This means watching the calendar until you are clear of audit. Unless you skip filing taxes entirely, you might assume your risk of audit eventually passes.

Taxpayers with a unreported income  from  a foreign bank account  find that this situation  is tough to resolve. The safest approach is going into the IRS Offshore Voluntary Disclosure Program, although some clients opt for more aggressive approaches.


Failure to file any one of the various foreign information reporting forms (e.g. 5471, 3520, 8838, etc.) leaves the statute of limitations open for every item in the associated federal income tax return.

Besides the various $10,000 penalty per year, per report, associated with each failure file a foreign information report;  the statute of limitations for the IRS to discover and  assess tax on the associated with  federal return remains open indefinitely and thereby creates a double whammy.

These $10,000 penalty per year, per report, associated with each failure file a foreign information report; apply even where no additional tax is due.


Have Un-Reported Offshore Income?

Value Your Freedom?
 
 
Contact the Tax Lawyers at
Marini & Associates, P.A.
  
for a FREE Tax Consultation Contact US at
or Toll Free at 888-8TaxAid (888 882-9243




Source:

Forbes

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