The Russian FBAR
If Putin is folllowing your example, you are NOT a redneck. You may, however, be a statist running rough shod over personal liberty.
Russian FBAR filing requirement to commence January 2, 2015.
This IRSMedic blog! For immediate tax help call 888-IRS-HALT (888-477-4258) or email info@irsmedic.com
Friday, December 26, 2014
Tuesday, November 25, 2014
US taxation of Foreign Income
US taxation of Foreign Income
A great perspective on US taxation of foreign income from our Ukranian-born Director of Tax Compliance, Vladyslav Golubovskyi. No other country is as "exceptionally" horrible to worldwide income as the USA.
A great perspective on US taxation of foreign income from our Ukranian-born Director of Tax Compliance, Vladyslav Golubovskyi. No other country is as "exceptionally" horrible to worldwide income as the USA.
Thursday, November 13, 2014
Use These Four Tips to Maximize the Chance of Getting Your Offer in Compromise Accepted
The IRS Offer in Compromise program is the most popular and approved way to resolve delinquent tax liabilities. Unfortunately, the IRS made the qualification requirements so difficult that only fewer people offer gets accepted or they were made to pay out too much money to the federal government. In this post, we have provided an overview of a few tips that will help put an end to your long-standing IRS tax issue.
OIC Tip #1: Standard or the Actual Expense?
Irrespective of your actual expenses, the IRS have got guidelines on exactly how much you can designate as living expenses. You need to know when the IRS will approve expenses above their maximum limit and when they won’t. While arguing for an expense which is more than the national standards, you have to provide relevant documentation and also have to prove why they are necessary. Know what the IRS considers ordinary and necessary. The outcome can be that you weren't qualified for an offer, or it had no chance of approval simply because you didn’t understand the procedures. Also, you have to determine whether to makes use of the IRS Standards deduction or the actual expense deduction to receive maximum tax benefit.
OIC Tip #2: Reduce Equity Positions
Figure out ways to lower equity in your assets. Don't be tempted to overvalue your assets. Take full advantage of allowed tax deductions and know how to maximize your deductible business expenses. Make use of all possible deductions for vehicle expenses that include fuel, repair and maintenance. While claiming write-offs for automobile operating expenses, weigh up which of the IRS method - standard mileage expense or the actual car expenses gives you a bigger tax deduction. The Internal Revenue Service will view the money in your retirement savings account as an asset and will be valued during the OIC evaluation. Check out the limits of liquidating or borrowing money from retirement account and learn how converting the equity into a future stream of income could benefit you directly.
OIC Tip #3: Use the IRS Statute of Limitations to Your Advantage
Knowing how much time is leftover on statute of limitations (CSED) is extremely important, as this could have a huge influence on the entire process. If the Collection Statute Expiration Date (CSED) is near, rather than gambling on to retrieve the pending taxes, the IRS would really consider accepting your Offer in Compromise.
OIC Tip #4: Don’t Hesitate to Appeal if Your Offer is rejected
Obtain the copies of collection's Income/Expense Table and also the Assets/Equity Table from the IRS in case your offer was rejected. If you find any mistakes or if the Offer examiner did not follow the IRS guidelines exactly, you may appeal for a review of the determination. If you believe the assets value is not correct, dispute them with the latest appraisals. In case the income/expense is not correct, give additional supportive documentation at this stage. If the Offer in compromise isn't accepted, there are other alternative solutions available that you can make use of through appeal.
The Realities of OIC program
The Offer in Compromise program could be your excellent way to address the taxes owed, leading to a fresh start with the Internal Revenue Service. But, the process is very comprehensive and complicated that require great attention to detail, knowledge of numerous IRS rules, procedures and tax laws. Submitting an OIC or handling your own case might end up costing you even more than the original tax debt owed. All these tips are just basic outlines and there are actually a lot of tricks of the trade. Furthermore, Offer in Compromise is not for everyone. Plus there exist negative consequences to filing an offer when there is no realistic chance of its success. By utilizing the services of a trusted tax resolution firm, the tax attorney will stand up to the IRS on your behalf and help you put your tax debt problems behind you right away.
Sunday, November 9, 2014
The devasting failure of the Bank Secrecy Act of 1970
The devasting failure of the Bank Secrecy Act of 1970
In 1970, the Bank Secrecy Act triggered FBAR filing requirements for accounts over $10,000. Yet. Did inflation not happen? Let’s assume $10,000 was magical sum of money that should create a presumption of illegal activity. But you know, in these past 44 years, like a lot of stuff has totally happened. One thing that happened is that I my broke my ankle on the first day of summer vacation in 1985 (true story). But another more relevant (and perhaps less tragic) event was inflation. That $10,000 of 1970, is now, as of this writing, $61,348.20 according to the government’s own inflation calculator. So shouldn’t the reporting requirements account for inflation?
In 1970, the Bank Secrecy Act triggered FBAR filing requirements for accounts over $10,000. Yet. Did inflation not happen? Let’s assume $10,000 was magical sum of money that should create a presumption of illegal activity. But you know, in these past 44 years, like a lot of stuff has totally happened. One thing that happened is that I my broke my ankle on the first day of summer vacation in 1985 (true story). But another more relevant (and perhaps less tragic) event was inflation. That $10,000 of 1970, is now, as of this writing, $61,348.20 according to the government’s own inflation calculator. So shouldn’t the reporting requirements account for inflation?
Monday, November 3, 2014
IRS collection process
IRS collection process
Whether you have just learned that you owe money to the IRS, or have had
a lingering tax problem for many years, in this article we will explain
the three phases of the IRS collection process (Cf., The Five Stages of Grief and Loss).
But first, we need to give you a little background so you can determine
when and how the IRS will start “enforced” collections (that is
levying, garnishing you so hard you won’t be able to sit down). Also,
hopefully to give you knowledge that will empower you so that you will
not be intimidated into paying back the IRS something that is
unreasonable.
Whether you have just learned that you owe money to the IRS, or have had
a lingering tax problem for many years, in this article we will explain
the three phases of the IRS collection process (Cf., The Five Stages of Grief and Loss).
But first, we need to give you a little background so you can determine
when and how the IRS will start “enforced” collections (that is
levying, garnishing you so hard you won’t be able to sit down). Also,
hopefully to give you knowledge that will empower you so that you will
not be intimidated into paying back the IRS something that is
unreasonable.
Wednesday, October 29, 2014
IRS PFIC rules
IRS PFIC rules
Do you own Foreign Mutual Funds? I got some bad news --- you have some horribly expensive accounting work to do for the IRS. , I can’t say what the cleaned-up “official” reason is, but I can tell you what the real reason is: Protectionism. PFIC language was snuck into Section 1291 of the Tax Reform Act of 1986 as a protectionist measure for the the US-based mutual fund industry (sorry Reagan fanboys — or maybe we can blame this on his Democrat rival Tip O’Neil?) . Entrenched Wall Street interests hated the fact that offshore mutual funds had a strategic advantage over domestic funds, with lower costs and higher returns, as foreign funds do not have to jump through the (editorial content warning) expensive, asinine hoops of the Securities and Exchange Commission (SEC). So instead of getting rid of the SEC (and all those federal jobs), Congress decided to intentionally make Foreign Mutual Funds less attractive by requiring expensive, mind-bloggling PFIC accounting. So everyone wins, the person who like to invest overseas.
Do you own Foreign Mutual Funds? I got some bad news --- you have some horribly expensive accounting work to do for the IRS. , I can’t say what the cleaned-up “official” reason is, but I can tell you what the real reason is: Protectionism. PFIC language was snuck into Section 1291 of the Tax Reform Act of 1986 as a protectionist measure for the the US-based mutual fund industry (sorry Reagan fanboys — or maybe we can blame this on his Democrat rival Tip O’Neil?) . Entrenched Wall Street interests hated the fact that offshore mutual funds had a strategic advantage over domestic funds, with lower costs and higher returns, as foreign funds do not have to jump through the (editorial content warning) expensive, asinine hoops of the Securities and Exchange Commission (SEC). So instead of getting rid of the SEC (and all those federal jobs), Congress decided to intentionally make Foreign Mutual Funds less attractive by requiring expensive, mind-bloggling PFIC accounting. So everyone wins, the person who like to invest overseas.
Tuesday, October 28, 2014
IRS Fresh Start program
IRS Fresh Start program
This past weekend, I found myself in a movie theater. Don't alarm yourself. It was intentional, I assure you. True, I have not intentionally
been in a movie theater since the release of Turk 182 (or
there-abouts), and I remarked to my wife (my lovely date) about how
things changed since the go-go days of the Reagan administration. Now
one thing I noticed, aside from and terrible absence of any John Hughes
movies, was an audio recording playing in the hallway as we were about
take to our stadium seating. And why, it wasn't music. Why, it wasn't a
movie promotion. But rather, it was an advertisement. I heard a
professional voice, with a deep, relaxed timbre of authority, tell me
"If you owe $10,000 or more to the IRS, find out if the IRS Fresh Start program can help you today. Call 888 IRS HALT* for a free consultation right now!"
This past weekend, I found myself in a movie theater. Don't alarm yourself. It was intentional, I assure you. True, I have not intentionally
been in a movie theater since the release of Turk 182 (or
there-abouts), and I remarked to my wife (my lovely date) about how
things changed since the go-go days of the Reagan administration. Now
one thing I noticed, aside from and terrible absence of any John Hughes
movies, was an audio recording playing in the hallway as we were about
take to our stadium seating. And why, it wasn't music. Why, it wasn't a
movie promotion. But rather, it was an advertisement. I heard a
professional voice, with a deep, relaxed timbre of authority, tell me
"If you owe $10,000 or more to the IRS, find out if the IRS Fresh Start program can help you today. Call 888 IRS HALT* for a free consultation right now!"
Thursday, October 23, 2014
Delinquent FBAR filing procedures
Delinquent FBAR filing procedures
For US expatriates who have reported all
foreign-sourced income, or did not have any foreign income to report,
the IRS has made the delinquent FBAR filing procedures *relatively*
straight-forward and *relatively* easy to understand. But here’s where
things get ugly. This is only true for taxpayers who do not have any unreported income in the last 3 years.
Things get complicated in situations where there in no unreported
income in the last three years, but unreported income in any one of the
three years prior. In this article we will demonstrate the apparent
contradictions, and offer strategies for the not-too uncommon issue of
having unreported foreign income, not in the last 3 years, but rather,
4-6 years ago.
For US expatriates who have reported all
foreign-sourced income, or did not have any foreign income to report,
the IRS has made the delinquent FBAR filing procedures *relatively*
straight-forward and *relatively* easy to understand. But here’s where
things get ugly. This is only true for taxpayers who do not have any unreported income in the last 3 years.
Things get complicated in situations where there in no unreported
income in the last three years, but unreported income in any one of the
three years prior. In this article we will demonstrate the apparent
contradictions, and offer strategies for the not-too uncommon issue of
having unreported foreign income, not in the last 3 years, but rather,
4-6 years ago.
Steamlined OVDP FAQs
Steamlined OVDP FAQs
The IRS published Domestic Streamlined OVDP FAQs
on October 8, 2014 — purportedly to clear the air. The IRS is
attempting to be intelligent and foresee the questions people will ask.
The problem is we only see more confusion. Read more to judge for
yourself. Commentary is interspersed with italics, to denote possible future changes, or items of inconsistency.
The IRS published Domestic Streamlined OVDP FAQs
on October 8, 2014 — purportedly to clear the air. The IRS is
attempting to be intelligent and foresee the questions people will ask.
The problem is we only see more confusion. Read more to judge for
yourself. Commentary is interspersed with italics, to denote possible future changes, or items of inconsistency.
Tuesday, October 7, 2014
Understanding the Eligibility Requirements for the Streamlined Foreign Offshore Procedures
To ease the process for qualifying tax applicants, new changes have been introduced to the Streamlined Foreign Offshore Procedures. A 0% offshore penalty by default is a key benefit of the new program. In this article, we discuss about the expanded streamlined filing compliance process and the steps to find whether the taxpayer qualifies for the new streamlined program.
The Modified Streamlined Foreign Offshore OVDP Eligibility
• Must be individual taxpayers, including estates of individual taxpayers
• Taxpayers must certify that the failure to report foreign assets, and pay all tax on income from those assets was not a result of willful conduct.
• Will not be eligible to use the streamlined procedures, if the IRS has initiated a civil examination or criminal investigation of a taxpayer's information returns for any tax year.
• “Quiet Disclosures” made outside of the OVDP still eligible for streamlined procedures but any penalty assessments previously made will not be removed.
• Must have any one of the valid Taxpayer Identification Number (TIN) - SSN or ITIN or an ITIN application for some cases.
• Taxpayers who, AFTER July 1, 2014, submitted their intake letter/attachments cannot benefit from this new program. This is a huge thing for those who have filed a pre-clearance previously. If you want to get qualified for the Streamlined Procedure, just stay away from OVDP intake letter or disclosure. If you do, the OVDP opt-out will become the only option for you to reduce offshore penalties. Those who have submitted an OVDP submission prior to July 1, 2014, may qualify for the Streamlined Procedures pursuant to transitional rules under OVDP.
Non-Residency Requirements
• Non Residency requirement for U.S. citizens and lawful permanent residents: In any one or more of the three recent years for which the tax return deadline has passed, the individual did not have a US abode and he or she was physically present outside the U.S. for minimum 330 days. "Abode" refers to one's home, habitation, or place of dwelling but it does not mean the same as "tax home".
• For individuals who are not U.S. citizens or lawful permanent residents: If, in any one or more of the last 3 years for which the U.S. tax return due date (or a properly extended due date) has passed, the individual did not meet the "substantial presence test". For more details about this test, see IRS Publication 519.
Streamlined OVDP Procedures
1. For each of the past 3 years for US tax return due date has passed:
• If the U.S tax return filing was not done earlier, submit a new delinquent tax return using U.S. Individual Income Tax Return Form 1040, along with other required returns even though these information returns would normally be filed separately.
• If tax return has been filed previously, submit a complete amended tax return (using Form 1040X) together with the required information returns. Normally, information returns would be submitted separately had the taxpayer filed an accurate original return.
• Include “Streamlined Foreign Offshore” written in RED at the top of the first page of each amended or delinquent tax return and at the top of each information return. This will ensure the returns get processed under special procedures.
Certification of non-willful conduct
Willfulness requires more than checking the incorrect or no box on a Schedule B. Willfulness is not just about non-filing of FBAR. It is highly recommended to get a legal advice from an OVDP Attorney on your non-willfulness or willfulness.
File delinquent FBARs
File delinquent FBARs (FinCEN Form 114) for each of the past 6 years for which the FBAR filing due date has passed with explanation "Streamlined Filing Compliance Procedures".
Monday, September 29, 2014
IRS Jeopardy Assessment
IRS Jeopardy Assessment
Far removed from the full-filled half hour that we associate with a Merv Griffith-created game show called Jeopardy!, "jeopardy," when referring to the IRS, leaves little room for entertainment. In fact, it can mark the beginning of an significant escalation of a tax problem. You see, a “Jeopardy Assessment” is made when the IRS feels, (yes, the IRS has feelings) it is at risk of losing its hard-earned money because a taxpayer (or someone who holds cash of another taxpayer) is going to take some sort of action that will make it difficult for the IRS later collect.
Far removed from the full-filled half hour that we associate with a Merv Griffith-created game show called Jeopardy!, "jeopardy," when referring to the IRS, leaves little room for entertainment. In fact, it can mark the beginning of an significant escalation of a tax problem. You see, a “Jeopardy Assessment” is made when the IRS feels, (yes, the IRS has feelings) it is at risk of losing its hard-earned money because a taxpayer (or someone who holds cash of another taxpayer) is going to take some sort of action that will make it difficult for the IRS later collect.
Wednesday, September 24, 2014
Oh Great. Now There Is A FATCA Scam Too
Oh Great. Now There Is A FATCA Scam Too
You may detect a
certain tone in this article regarding the FATCA scam, indicating that
this writer believes FATCA was a huge mistake. That detection would be
correct. Yet, while we may snark at Commissioner Koskinen
— who has the potential to break the irony meter with this quote, from
above: “[p]eople should always be cautious about sending sensitive
information to anyone.” In fact, the entire FATCA misery lands squarely
at the feet of those who voted for it. The IRS did not create FATCA, and
in fact, the IRS has introduced and is responsible for exactly 0% of
all tax laws. The IRS should not be the scapegoat, but rather the 217 Democrats in the House of Representatives, the 55 Democrats, 11 Republicans(!) and 3 independents in the Senate, and the one President who ratified this terrible, terrible bill.
You may detect a
certain tone in this article regarding the FATCA scam, indicating that
this writer believes FATCA was a huge mistake. That detection would be
correct. Yet, while we may snark at Commissioner Koskinen
— who has the potential to break the irony meter with this quote, from
above: “[p]eople should always be cautious about sending sensitive
information to anyone.” In fact, the entire FATCA misery lands squarely
at the feet of those who voted for it. The IRS did not create FATCA, and
in fact, the IRS has introduced and is responsible for exactly 0% of
all tax laws. The IRS should not be the scapegoat, but rather the 217 Democrats in the House of Representatives, the 55 Democrats, 11 Republicans(!) and 3 independents in the Senate, and the one President who ratified this terrible, terrible bill.
Monday, September 22, 2014
OVDP streamlined procedures willful blindness
OVDP streamlined procedures willful blindness
"The IRS is not a person. It does not have a conscience. It does not
stay up at night worrying if people like it. The IRS is simply a system
where people follow orders. In all reality, the IRS has no problem
ruining you. And the naivety of otherwise smart, intelligent,
hard-working people to understand this — well, this — you even have
that nightmare where you’re trying to yell to a loved-one so they can
avoid impending harm, but you can’t make a sound? Well that’s what it
seems like some days when people tell us they are going to try handling a
problem themselves or with an under-powered representative."
"The IRS is not a person. It does not have a conscience. It does not
stay up at night worrying if people like it. The IRS is simply a system
where people follow orders. In all reality, the IRS has no problem
ruining you. And the naivety of otherwise smart, intelligent,
hard-working people to understand this — well, this — you even have
that nightmare where you’re trying to yell to a loved-one so they can
avoid impending harm, but you can’t make a sound? Well that’s what it
seems like some days when people tell us they are going to try handling a
problem themselves or with an under-powered representative."
Tuesday, September 16, 2014
Calculating a willful FBAR penalty
Calculating a willful FBAR penalty
The purpose of the FBAR form was to give Treasury an E-Z way to penalize
the worst of the worst. But the worst of the worst, if they read the
law carefully can avoid having a foreign account with any balance
subject to an willful FBAR non-filing. You see, 50% of $0 = $0 Sure,
there are a whole bunch of other laws being broken, but isn't the entire
rationale for requiring self-reporting of foreign bank account
completely undermined?
The purpose of the FBAR form was to give Treasury an E-Z way to penalize
the worst of the worst. But the worst of the worst, if they read the
law carefully can avoid having a foreign account with any balance
subject to an willful FBAR non-filing. You see, 50% of $0 = $0 Sure,
there are a whole bunch of other laws being broken, but isn't the entire
rationale for requiring self-reporting of foreign bank account
completely undermined?
Monday, September 15, 2014
Estimated Tax payments
Estimated Tax payments
In a perfect world, no one would ever run
short of cash and there would be enough to pay everyone. But that isn’t
reality, is it? So at some point, you need to prioritize. Should you
pay an old tax debt or your current payments? Should you pay other debt
or your estimated tax payments. Here is the most important thing I want
you to get form this article: When push comes to shove, pay your current estimated tax payments first! Old tax a debts can all be negotiated. Future tax problems can not be.
In a perfect world, no one would ever run
short of cash and there would be enough to pay everyone. But that isn’t
reality, is it? So at some point, you need to prioritize. Should you
pay an old tax debt or your current payments? Should you pay other debt
or your estimated tax payments. Here is the most important thing I want
you to get form this article: When push comes to shove, pay your current estimated tax payments first! Old tax a debts can all be negotiated. Future tax problems can not be.
Thursday, September 11, 2014
Tuesday, September 2, 2014
Wednesday, August 20, 2014
Federal Tax Evasion
Federal Tax Evasion
The IRS as well as DOJ have the upper hand in the huge event it arrives to become able to tax evasion as well as other federal tax crimes.
If your IRS Criminal Investigation Division investigates you, there is actually a 90% opportunity they will seek an indictment. In case they will seek an indictment, there is a 94% likelihood the Grand Jury will return an indictment. In case they provide an indictment, there's a 93% chance that you will plead guilty or maybe be found guilty.
There are generally thousands regarding people the actual IRS could select with regard to criminal prosecution every year, however the truth is, they will are only in any position to method with regards to 3000 new criminal cases the year. so the actual IRS must rule simply by worry and also intimidation with all the people the actual do snare inside their nets.
Another benefit the actual IRS provides is that jurors as well as idol judges often favor your government. They Will can't imagine why anyone would possess a problem filing along with paying their own taxes about time. Jurors and also all judges tend to look in the IRS as good guys --- the particular IRS is the place idol judges acquire paid, and for most jurors, they will never, ever were required to personally create a new check to the IRS. all these people obtain in the IRS can be refund checks.
And if you count on expert advice, if you do not understand every little thing in your tax return, too bad. Your law imputes knowledge you might by absolutely no means possess.
So the approach to avoid the trap?
Don't be among the thousands of people within current non-compliance with most the IRS. Always Be sure anyone enter into compliance, work together with a voluntary disclosure plan is actually necessary, get in to a collection alternative should you owe the IRS money. And Also in the large event you are generally looking for tax cost savings always be conscious that if a tax shelter moves bad, the individual most more most likely to testify against you in a criminal case will be your promoters with the tax shelter, if it can be a banker, any CPA or even a tax attorney. the collection in between was is allowable along with criminal will be razor thin and not always any straight line. Consequently end up being incredibly cautious.
If you do end up together with within indictment, be conscious of for you to mount the ideal defense, an individual is likely to be spending a massive variety of 1000s of dollars, on the lead attorney, neighborhood attorney, accountant, and expert witnesses, as well as support attorneys like our firm.
Unfortunately, just simply because someone is expensive, will not man they possess won any trials. Don't always be impresses using a name, or maybe an workplace constructing or how huge a new firm is. Anytime interviewing fro your current lead attorney, question them how many trials that they took for you to verdict, and just how many they've got won.
No criminal attorney can guarantee a new win. What a person protection team are capable involving doing can be every 1 regarding the right things that increase a person chance of acquittal, dismissal or perhaps reversal on appeal. Also, having an aggressive tax defense team will increase your chances of an much more favorable plea deal, if necessary.
There are generally thousands regarding people the actual IRS could select with regard to criminal prosecution every year, however the truth is, they will are only in any position to method with regards to 3000 new criminal cases the year. so the actual IRS must rule simply by worry and also intimidation with all the people the actual do snare inside their nets.
Another benefit the actual IRS provides is that jurors as well as idol judges often favor your government. They Will can't imagine why anyone would possess a problem filing along with paying their own taxes about time. Jurors and also all judges tend to look in the IRS as good guys --- the particular IRS is the place idol judges acquire paid, and for most jurors, they will never, ever were required to personally create a new check to the IRS. all these people obtain in the IRS can be refund checks.
And if you count on expert advice, if you do not understand every little thing in your tax return, too bad. Your law imputes knowledge you might by absolutely no means possess.
So the approach to avoid the trap?
Don't be among the thousands of people within current non-compliance with most the IRS. Always Be sure anyone enter into compliance, work together with a voluntary disclosure plan is actually necessary, get in to a collection alternative should you owe the IRS money. And Also in the large event you are generally looking for tax cost savings always be conscious that if a tax shelter moves bad, the individual most more most likely to testify against you in a criminal case will be your promoters with the tax shelter, if it can be a banker, any CPA or even a tax attorney. the collection in between was is allowable along with criminal will be razor thin and not always any straight line. Consequently end up being incredibly cautious.
If you do end up together with within indictment, be conscious of for you to mount the ideal defense, an individual is likely to be spending a massive variety of 1000s of dollars, on the lead attorney, neighborhood attorney, accountant, and expert witnesses, as well as support attorneys like our firm.
Unfortunately, just simply because someone is expensive, will not man they possess won any trials. Don't always be impresses using a name, or maybe an workplace constructing or how huge a new firm is. Anytime interviewing fro your current lead attorney, question them how many trials that they took for you to verdict, and just how many they've got won.
No criminal attorney can guarantee a new win. What a person protection team are capable involving doing can be every 1 regarding the right things that increase a person chance of acquittal, dismissal or perhaps reversal on appeal. Also, having an aggressive tax defense team will increase your chances of an much more favorable plea deal, if necessary.
Tuesday, August 19, 2014
Can I deal with the IRS myself?
Can I deal with the IRS myself?
There are a few difficulties when dealing with the IRS yourself.
The first is, should you? The problem is that it might not be apparant to you that you have a significant tax problem that requires the skills of a tax lawyer who will be on your side.
Another issue is that the IRS does not have integrated communications and document sharing abilities. So just becuase you told something to one person at the IRS, does not mean someone else will know what you said.
IRS employees are over-regulated. That is, they have so many rules to follow, they can lose focus of the most important objective. And every day there seems to be yet another rule to follow.
IRS employees represent the government. They are not allowed to give you advice on your best course of action even if they want to (some do break these rules).
The IRS routinely makes mistakes. It is an agency with too much to do, and yet, is now required to do even more now that ObamaCare is the law of the land.
The IRS field offices are understaffed. So that means even if a Revenue Officer wants to accept your alternative, it will take them more time to review and document and properly process your collection alternative.
Some of the most difficult types of agreements to get the IRS to actually accept and process properly are installment agreements! That's right --- just getting a payment plan with the IRS can be a unbelievable ordeal for the layperson --- especially if they owe the IRS over $50,000.
There are a few difficulties when dealing with the IRS yourself.
The first is, should you? The problem is that it might not be apparant to you that you have a significant tax problem that requires the skills of a tax lawyer who will be on your side.
Another issue is that the IRS does not have integrated communications and document sharing abilities. So just becuase you told something to one person at the IRS, does not mean someone else will know what you said.
IRS employees are over-regulated. That is, they have so many rules to follow, they can lose focus of the most important objective. And every day there seems to be yet another rule to follow.
IRS employees represent the government. They are not allowed to give you advice on your best course of action even if they want to (some do break these rules).
The IRS routinely makes mistakes. It is an agency with too much to do, and yet, is now required to do even more now that ObamaCare is the law of the land.
The IRS field offices are understaffed. So that means even if a Revenue Officer wants to accept your alternative, it will take them more time to review and document and properly process your collection alternative.
Some of the most difficult types of agreements to get the IRS to actually accept and process properly are installment agreements! That's right --- just getting a payment plan with the IRS can be a unbelievable ordeal for the layperson --- especially if they owe the IRS over $50,000.
Wednesday, July 30, 2014
Tuesday, July 22, 2014
Monday, July 21, 2014
Thursday, July 17, 2014
IRS OVDP for corporations and other entities, domestic or offshore
IRS OVDP for corporations and other entities, domestic or offshore
That was a stat given to me by an OVDI examiner back in 2010. She told me that the IRS believed that 70% of unreported foreign accounts were held in the name of corporations, partnerships, trusts, llcs, and foundations, as an additional barrier to avoid detection.
Myself --- I think this number is off. I think the IRS completely miscalculated the amount of innocent minnows who held account in their own name.
In this article I discuss the various paths to compliance for foreign vs. domestic domiciled or registered entities. In other words, does the individual have to go through OVDP, the entity or both?
That was a stat given to me by an OVDI examiner back in 2010. She told me that the IRS believed that 70% of unreported foreign accounts were held in the name of corporations, partnerships, trusts, llcs, and foundations, as an additional barrier to avoid detection.
Myself --- I think this number is off. I think the IRS completely miscalculated the amount of innocent minnows who held account in their own name.
In this article I discuss the various paths to compliance for foreign vs. domestic domiciled or registered entities. In other words, does the individual have to go through OVDP, the entity or both?
Tuesday, July 15, 2014
Four Offer in Compromise Tips
Four Offer in Compromise Tips
Did you know that 75% of Offers in Compromises submitted are rejected?
And of those that are accepted, how many times have taxpayers paid more than they needed to?
In this video and article, I give some great tips to get an optimal offer in compromise accepted by the IRS. Like:
Making sure you are aware of the allowable expenses and have explanations for the expenses that are over the allowable.
Making sure you took the most beneficial snap shot of your financial picture as legally possible.
Making sure you have properly addressed any equity positions WITHOUT dissipating assets.
In the case of rejecting, knowing how to request an expense, income and asset table from the OIC examiner to maximize your chances of success on appeal, or an alternative resolution.
Did you know that 75% of Offers in Compromises submitted are rejected?
And of those that are accepted, how many times have taxpayers paid more than they needed to?
In this video and article, I give some great tips to get an optimal offer in compromise accepted by the IRS. Like:
Making sure you are aware of the allowable expenses and have explanations for the expenses that are over the allowable.
Making sure you took the most beneficial snap shot of your financial picture as legally possible.
Making sure you have properly addressed any equity positions WITHOUT dissipating assets.
In the case of rejecting, knowing how to request an expense, income and asset table from the OIC examiner to maximize your chances of success on appeal, or an alternative resolution.
Monday, July 14, 2014
Saturday, July 12, 2014
Thursday, July 10, 2014
Tuesday, July 8, 2014
Monday, July 7, 2014
How easy is it to freeze a Swiss bank account?
How easy is it to freeze a Swiss bank account?
Easy. If you ignore a letter from your Swiss bank telling you that they are going to freeze your account.
Easy. If you ignore a letter from your Swiss bank telling you that they are going to freeze your account.
Saturday, June 28, 2014
Tax Debt Relief: Know Your IRS Tax Settlement Options
The IRS offers numerous settlement options to taxpayers who are struggling to settle their tax owed. In this post, we will discuss about the advantages and disadvantages of some of the most common IRS tax settlement options.
1. Audit Reconsideration
Advantages: There are many situations in which a taxpayer may qualify for this option. Even in cases where the time limit to appeal is expired, the taxpayer can still request audit reconsideration.
Drawbacks: Your tax return should be audited originally and you should have valid reasons with evidence for not attending the audit. The process can take very long and sometimes, you may be required to appeal.
2. Full Payment Installment Agreement
Advantages: An easiest settlement plan to obtain, a full payment installment agreement can help avoid levies and garnishments. Liens will be withdrawn once full payment of taxes is made.
Drawbacks: A collection information statement is required, if the tax amount owed is over $25,000. One biggest drawback is that the interest and penalties will continue to accrue while you still owe. You may get limited time to repay and the IRS can also file a tax lien, when needed.
3. Partial Pay Installment Agreement (PPIA)
Advantages: Partial Payment Installment Agreement allows taxpayers to pay an affordable monthly payment, based on their financial situation. It is easier to obtain than an offer in compromise and you settle the debt for less than the total amount owed.
Drawbacks: It requires full financial disclosure and you will be even required to pay down your debt with any liquid assets. The IRS will reassess your financial situation every so often. Furthermore, the federal tax lien and its impact remain in place right until the expiration of the collection period.
4. Penalty Abatement
Advantages: Tax penalties that start out as a small amount can quickly spiral out of control, so in certain cases, a penalty abatement can stop the accrual, or even remove them completely.
Drawbacks: For many, penalty abatement isn't an appropriate solution because of their bad history of non-compliance. Even if you qualify, you still need to pay the base amount of owed tax in full.
5. IRS Offer in Compromise
Advantages: An offer in compromise allows the taxpayer to pay a reduced amount of the original tax liability. During the negotiation process, the IRS will suspend collection activity and when accepted, any tax liens on the taxpayer’s property will be lifted.
Drawbacks: This offer in compromise program is not for everyone and it can be difficult to get approved. The OIC will be kept in the public records for a year or more. The IRS has the right to intercept your tax refund and any payments you make. For a period of 5 years from the time the IRS accepts your offer, you must stay current with tax filings and payments. If not, the IRS has the power to revoke the Offer.
6. Currently-Non-Collectible (CNC)
Advantages: This plan will prevent all "enforced collection" activity from the IRS (like levies and garnishments) and you don't have to pay any monthly payments till your financial condition improves.
Drawbacks: The drawback of “Non-collectible" status is that all outstanding liabilities will continue to accrue interest and penalties. This option will provide some temporary relief but does not solve all of your tax problems.
7. Bankruptcy
Advantages: Chapter 7 bankruptcy allows full discharge of older tax debts. The process is really quick; a taxpayer can receive a bankruptcy discharge within 4 months of filing.
Drawbacks: Trust fund taxes are not dischargeable in Chapter 7 bankruptcy. It will damage your credit rating drastically. Even in bankruptcy, the tax lien will not go away.
Sunday, May 11, 2014
Tax help for IRS FBAR Problem – Attorney and Tax Resolution
We know exactly how you must be feeling. You perhaps just discovered about this IRS FBAR form and your surprise is well-justified: The United States of America stands out as the only country that tax its people for their world-wide income. Even worse, the IRS provides no exceptions for expatriates, dual citizens, resident aliens, and H-1B VISA holders. As a matter of fact, the only other nation that taxes income in the same way is North Korea!
So if you're new, or not so new, to the United States, your failure to file FBARs and report your overseas income is completely understandable.
Complicated FBAR form
In our IRS FBAR blog site - which is actually read by thousands of tax payers and tax experts - we've written at length about how complex the FBAR guidelines are. Not only you are expected to be familiar with the IRS’ really weird taxation program, you're also expected to understand the requirements of the tricky IRS FBAR form. The FBAR format changes each and every year, and yet you're still expected to fully understand your obligations.
Even worse, it's hard to get someone qualified to assist you. We have seen a lot of tax payers who thought that they were completing it in the correct way and found out they weren’t.
It is not just the FBAR form all you have to worry about
Partnerships, Foreign Corporations, and Foreign Trusts all have got their FBAR equivalent forms with corresponding penalty charges. Forms that include Form 5471, Form 5472, Form 8891, and Form 3250 also have complex filing requirements and substantial penalties if it is not done properly.
FBAR is extremely specialized
This system is not really fair. You have to understand that. You also want an IRS FBAR lawyer, working with you, who knows precisely how you are feeling. You require a law firm that has successfully closed a lot of OVDP and other FBAR cases.
Regrettably, we have seen FBAR cases mishandled by lawyers and Certified Public Accountants who “dabbled” in FBAR problems. We are regularly called in to solve issues that never ever should have occurred. It is best, nevertheless, when an FBAR case is handled correctly in the first place.
Do you need a highly qualified FBAR Attorney?
At IRSMedic: We are a specialized tax resolution firm, having our very own dedicated off-shore disclosure and FBAR penalty department. Since the very first Offshore Voluntary Disclosure Initiative in the year 2009, our firm has helped several thousand American taxpayers deal with their un-filed FBARs, unfiled tax returns, unreported income and FBAR penalty abatement.
We have helped tax payers from all over the nation, with plenty of clients from Dallas, Houston, San Jose, San Francisco, Connecticut, Los Angeles, New Jersey, Atlanta, San Diego, Miami, Washington DC, and New York.
Our firm has helped expatriates and dual citizens with their US taxes from the United Kingdom, Belgium, Australia, New Zealand, France, Switzerland, Ireland Spain, Dubai, Iran, Germany, Italy, Brazil, Panama, Mexico, Argentina, India, Singapore, Canada, Hong Kong, China, Japan, South Korea and Thailand.
The excellent news: You can certainly put this behind you
Professional FBAR legal representation is actually difficult to find. We know you like to get the FBAR problems right behind you forever! You would like to move up with your life rather than carry on living in fear of what the Internal Revenue Service is planning to do. The great news is our firm has helped others in very similar scenarios and we could also help you personally.
Thursday, April 17, 2014
Don’t Make These Mistakes during Your Debt Settlement Negotiation with the IRS
People break out in cold sweat or start munching on antacid tablets as soon as they get that dreaded letter from the IRS. In fact, the IRS itself acknowledges that how intimidating the government agency can be. When individuals get a tax problem, many just want to escape from it or make the IRS get far away from them. Mistakes happen when they rush to get rid of their tax problems and this could cause much more harm to them in the long run.
This article will discuss about the five major IRS debt settlement mistakes taxpayers often make when they try to settle a debt with the Internal Revenue Service.
Mistake No.1: Not being up-to-date on tax payments
Whenever you approach the IRS to have negotiation for reducing your tax debts, the first thing the IRS will ask is "Have you been in current compliance with tax?” This means that you have to pay your taxes on a regular basis through withholding or you should make estimated tax payments and it must be up to date. Also you must have filed your tax returns up to the present year. If you are not able to comply with the tax rule, doing discussion with the IRS can become an unnerving exercise. During these times, it is best to get assistance from a tax lawyer to do the talking for you.
Mistake No.2: Thinking the IRS has your best interest
IRS employees represent the government. They work with the best interest for the federal agency and not to you. Regardless how good they may seem, their interest is to get as much money from you within the shortest period of time. Believing a revenue official is out to assist you can be a huge mistake.
Mistake No.3: Missing important information while filling forms
Many people are filling out forms 433-a, 433-b and 433-f just like filling tax return. What they need to understand is that these documents work as a great persuasive tool in reducing their tax debts. So it is crucial to get these documents done correctly.
The IRS will carefully scrutinize your financial ability to pay and future earnings potential before they agree for partial payment. So present your report with true information and never forget to include all of your expenses in the IRS financial forms or better get your documents reviewed by a tax specialist. If you overlook significant things like vital expenses, you will end up agreeing to an unaffordable plan.
Mistake No.4: Not looking at other settlement alternatives
The IRS Offer in Compromise program is certainly one tax resolution method that is getting all the publicity in recent years. While this program might work for some, it certainly does not work for all. There are several other options, like the Partial Payment Installment Agreement, that can work best on certain cases to minimize back taxes. Chapter 7 bankruptcy is another great tool for eliminating tax debts.
Like everybody, IRS employees also make mistakes. So if you disagree with any IRS action, you have the legal right to ask the IRS appeals office to look at the case. But there are time-sensitive deadlines for filing appeals. So to avoid potential adverse outcomes, it's always best to have an experienced tax lawyer handle the entire appeal process for you, from the filing process to debt settlement negotiations.
Saturday, March 15, 2014
IRS Tax Garnishment: What to Do
Facing an IRS garnishment is one of the most horrifying experiences in a person's life. When the Internal Revenue Service garnishes your income, you are forced into financial distress because they will take the majority of your earnings straight from your employer and also will seize your assets. This article will lay out the steps you need to take, at this time, to have your life back when confronted with an IRS tax garnishment.
What kind of garnishment?
If it is a bank garnishment, the IRS will freeze your bank accounts and take all money in the account equal to the total amount you owe. Initially the bank will hold the levied funds for 20 days before releasing it to the IRS, so you need to take action inside this time to have your money back.
If it is a wage garnishment, it is never too late to get the garnishment released, even if it has been on for years. Since the IRS will garnish significant portion of your income (and they won’t care about whether you have enough money to pay your monthly expenses), try to make use of all options available to get it removed as quickly as possible.
How you can get the garnishment released?
In order to get it back, you will need to contact the IRS staff who issued the garnishment to get all necessary information from them. Call up the IRS toll free number if your case is with the Automated Collection System. Anyone who answers can help you.
If your case is with a revenue officer, you will need to contact them in order to get your levy released.
What do you have to say?
The fact is, there is nothing much to speak about. Garnishments are serious business and are best left to tax attorneys experienced in negotiations. The IRS will do whatever they can to make you to pay an amount greater than what you can afford to pay. Remember, the IRS works for the government and not for you. So do not think that they'll help you in some way. They least worry about your financial situation but will try to make you pay out as much as possible. You won’t be left much to pay your other expenditures and to support your family.
At times, a person might unable to hire a tax lawyer immediately who primarily specializes in IRS garnishments. So below are a few quick tips to help you. Do not ever agree for an unaffordable payment plan even if the IRS uses pressure tactics in forcing you. You have the right to ask for a taxpayer advocate. You might get a release of your tax levy but remember it is temporary only. What this means is, you'll need what is known as a 'collection alternative' with the IRS so that you can resolve your case. Typical collection alternative include payments plans, hardship status requests, offers in compromise, and Chapter7 bankruptcy.
It is really essential that during this respite from the IRS tax garnishment, that you really work towards a long-term plan to take care of your tax debt. In case you fail to do so, the IRS will issue another garnishment and you will have really a hard time getting it released.
Saturday, March 8, 2014
Unfiled Tax Returns – Top Six Common Questions Answered
It's no surprise that there are several U.S. citizens who haven't filed their tax returns for years. Lots of people don't want to come forward and declare their unfiled taxes because they fear it'll bring in far more trouble to them. And many wonder how far back they need to go for their delinquent returns. People who don't have enough money to pay for the past tax dues wonder should they have to file the returns in any event or if it is better to wait until they can afford. Some are worried about whether they can be arrested and sent to prison for unfiled returns. People who plan to file bankruptcy or seeking out passport wonder whether they have to show filed tax returns or not. If you have similar questions like this about unfiled tax returns, read on the rest of the article to find the answers.
How far the Internal Revenue Service can go back to collect delinquent taxes?
Can you believe that in the event you don’t file a tax return, the IRS has forever to assess you taxes? That appears scary, but since the IRS has limited resources, the policy is that you should file for the past 6 years in order to become compliance. You need to know that every state has different statute of limitations and for certain cases, the IRS can look back even further. Here the expert assistance of a tax attorney is required.
Now, there is a complete turn-around. The IRS has become much better in finding US citizen’s income sources and actually, they can file Substitute Filed Return (SFR) on behalf of taxpayers. When you have SFRs against you, it is good to file return for those years, which may be well more than 6 years ago.
Do I have to file tax returns even if I am unable to pay the taxes I owe?
Without a question! It's not an offense to owe the IRS money, but it's a crime not to file your taxes.
And don’t wait until you can afford to pay the IRS to file your back tax forms. And the best time to have negotiation with the IRS is when you've got less amount of money to pay. This is called “Reasonable Collection Potential” (RCP) in IRS terms. Lower your RCP, the higher is going to be chance of getting favorable results.
What kind of penalties exists for unfiled returns?
The longer you wait to file your tax return the more money you will be charged in penalty charges as well as interest fees. This is how the IRS warns the non-filers:
“The failure-to-file penalty is generally more than the failure-to-pay penalty. So if you cannot pay all the taxes you owe, you should still file your tax return on time and pay as much as you can, then explore other payment options. The IRS will work with you.”
So not filing your tax return certainly will not make your situation any better. Always file and then you can make use of various tax solutions that help you to pay the owed taxes.
Would unfiled tax returns prevent me from getting a passport?
You won’t be denied a passport for having outstanding tax debts but the state government department may check with the IRS to see if you have unfiled taxes. The state government could refuse issuing a passport if your tax matters have been escalated. When the passport issuance is denied, you must pay the back taxes along with interest and penalties to have the denial removed.
Do I need to file my back tax returns when I'm filing bankruptcy?
Without a doubt! And also, did you know that you can file bankruptcy to discharge specific individual tax debts. But generally, it will only work if you filed for those years you expect the bankruptcy court to wipe out your IRS tax debts for. So even if the bankruptcy court didn’t ask you to file your old income tax returns, it is to your advantage to file any missing returns you haven’t.
How will I file the old tax returns when I don’t have all missing information?
The law only expects you to file missing returns that will be based upon the best of your knowledge. But you might ask “Where I can find the old income details?” Here, with the help of an IRS tax lawyer, you can find all the missing information. They will get the IRS W &I transcript and get all tax reporting forms like W -2’s and 1099s within couple of hours. The attorney will retrieve the old property tax bills from the city assessors. They will recreate profit and loss statements from your old bank statements.
Whatever your situation, do not ever ignore your tax return filing. Just file to protect yourself from getting nailed with big failure-to-file penalty.
Monday, February 10, 2014
Resolving IRS Garnishment and Other Tax Problems in Connecticut
Being the richest state per capita, Connecticut residents are facing the most difficulties when it comes to dealing with the Internal Revenue Service to get their tax problems resolved. This means that people in Connecticut are earning more money per individual than any other state in the United States. Therefore, if the IRS person who handles the tax issues is from another state, say Ohio, people will find very difficult to make them understand that earning $60,000 per annum will not make someone in Connecticut rich.
Since the fallout from the 2008 Wall Street crisis, Connecticut has been really struggling to regain its foothold. Also the dwelling cost continues to be increasing every year in the state and the local people were finding it hard to cope with it. To make the matter worse, taxes has been increased manifold as the government is paying more taxes per capita to maintain the states' quality lifestyle. But the fact is; we too have several poor people residing in the local towns whose earnings are much less that not even qualify for the taxes.
However the IRS is going after the taxpayers regardless of whether they reside in distressed areas like Bristol or in well-off metropolitan areas like Madison.
So if you contact an IRS agent for getting help with the release of an IRS tax levy or garnishment, you may not get the best solution from them since not every agent knows the actual costs of living in your city and exactly how much tax you can afford.
The IRS employees are trained to build strong cases against taxpayers who do not know about how to get their levy released and where to turn for tax relief help. And this is where you the need the guidance of an expert tax lawyer. These tax specialists will try every possible way to transfer your case to one of the two Connecticut appeal offices- East Hartford and New Haven. This is important because a local agent will get to know about your financial situation and can provide the best decision on the levy/garnishment release.
After the case is moved to one of the Connecticut IRS appeals locations, the next job of a professional IRS negotiator is to prove as many expenditures as possible are essential living expenses. To make this happen, the tax attorney will do lot of negotiation with the IRS employee. And even more so, there should be no lies. The IRS will stop negotiating with the taxpayer if they discover anything deemed unethical in the financial statements and will also initiate legal measures against them.
To put it succinctly, the taxpayer have to make efforts to ensure that the case is handled by the local appeal officials in order to get garnishment release in the state of Connecticut. Then a clear explanation should be made about the financial obligations and the amount that the taxpayer can afford to pay each month without defaulting.
Thursday, February 6, 2014
Part 6: The Offshore Voluntary Disclosure Program (OVDP) Process
Part 6: The Offshore Voluntary Disclosure Program (OVDP) Process
1500 word blog on the entire OVDP process. From pre-clearance to Title 31 warning letter. Writing about it nearly as exhausting as practicing it.
1500 word blog on the entire OVDP process. From pre-clearance to Title 31 warning letter. Writing about it nearly as exhausting as practicing it.
Wednesday, February 5, 2014
Thursday, January 30, 2014
Sunday, January 26, 2014
5 Things You Didn’t Know About FBAR Penalty Negotiations
Recently, the FBAR is in the spotlight since the IRS is having a new focus on the FBAR penalty enforcement actions. There are few important things that you have to keep in mind when negotiating FBAR penalties. The following paragraphs will explain them in a detailed manner.
1. FBAR penalties are staggering
The penalty can be draconian for taxpayers who have foreign accounts and have not reported it to the IRS. Higher the amount you have in overseas accounts, bigger will be the penalty. When compared with other IRS penalties, FBAR penalties can create huge risks to your financial well being. Therefore you must take this very seriously.
2. The two different kinds of FBAR penalties
The “ugly” FBAR penalty is $10,000. This penalty is assessed if the IRS thinks that you did not deliberately neglect to file an FBAR. And worse, there isn't anything to stop the IRS from assessing this innocent mistake penalty several times. If you have 4 unreported offshore accounts, the IRS can penalize you $40,000 a year. This is definitely outrage to us, but this is just what the law says.
The next type, "disastrous" penalty will be 50% of the offshore account value and this is applicable if it is an intentional avoidance of filing the FBAR. And similar to the “ugly“ FBAR penalty, it too can be assessed several times. This kind of multiple assessments by the IRS can wipe out you entire savings in matter of seconds.
3. The Internal Revenue Service doesn’t have to prove “willful neglect”
You are obligated to pay whatever penalty the IRS puts upon you. They might simply assume the "disastrous” penalty for your case and there isn't any necessity for the IRS to prove willfulness. It will be the taxpayers who bear the big burden of proving that their failure to comply was as a result of reasonable cause and not from “willful neglect”.
4. Appealing to a higher authority
You could file a suit in district court but before that, you need to exhaust your administrative remedies within the IRS. Or alternatively, you could pay out all the taxes before filing a suit for a refund. We strongly advise you to exhaust administrative remedies that are available in the IRS appeals process as this has lots of advantages. First, it's not necessary to pay any penalty till the process end. Second, you can find remedies from the IRS appellate process itself, making tax court unnecessary. In case, if you're not able to find a solution inside the IRS administrative remedies, a tax lawyer can find a receptive audience in IRS counsel and do negotiations with them. So without going to court trial, the FBAR penalties can be lowered.
5. The OVDP route
Earlier, people made use of Voluntary Disclosure Programs largely to avoid facing criminal prosecutions. The current OVDP/ FBAR Amnesty is there to help people by creating a standardized format for dealing with the threat of disastrous or ugly FBAR penalty charges. This is why it is important to make use of the OVDP to negotiate your FBAR penalties.
Initially by going through the OVDI, the review will be much more favorable to you during the discussion of your “FBAR reasonable cause" position. But outside the OVDP, the IRS does not treat people as favorably as those who make themselves visible under the OVDP. No matter whether you made an innocent mistake or made an unadvised “quiet” or “soft” disclosure, the ground will be much less sturdy when it is outside the OVDP.
Though criminal charges can be a threat to an individual, an IRS civil audit can do even more much damage to a taxpayer's financial well-being. While you may avoid facing prison time, these horrific FBAR penalties can easily wipe out your entire wealth as well. Within the OVDP, penalty charges are capped. You will never have to pay more than one 27.5% FBAR equivalent penalty.
Wednesday, January 15, 2014
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