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Delinquent International Information Return Submission Procedures

Posted by: Zaher Fallahi
Posted On: Aug 23, 2014

Taxpayers who do not need to use the OVDP http://zflegal.wpengine.com/blog/2012offshorevoluntarydisclosureprogram-1

or the Streamlined Filing Compliance Procedures http://zflegal.wpengine.com/blog/2012offshorevoluntarydisclosureprogram-1

http://zflegal.wpengine.com/blog/streamlinedfilingcomplianceprocedures to file delinquent or amended tax returns to report and pay additional tax, but who:

(1) have not filed one or more required international information returns,

(2) have reasonable cause for not timely filing the information returns,

(3) are not under a civil examination or a criminal investigation by the IRS, and

(4) have not already been contacted by the IRS about the delinquent information returns

should file the delinquent information returns with a statement of all facts establishing reasonable cause for the failure to file.  As part of the reasonable cause statement, taxpayers must also certify that any entity for which the information returns are being filed was not engaged in tax evasion.  If a reasonable cause statement is not attached to each delinquent information return filed, penalties may be assessed in accordance with existing procedures.

All delinquent international information returns other than Forms 3520 and 3520-A should be attached to an amended return and filed according to the applicable instructions for the amended return.  All delinquent Forms 3520 and 3520-A should be filed according to the applicable instructions for those forms.  A reasonable cause statement must be attached to each delinquent information return filed for which reasonable cause is being requested.

Information returns filed with amended returns will not be automatically subject to audit but may be selected for audit through the existing audit selection processes that are in place for any tax or information returns.

For assistance with disclosing your undeclared foreign bank accounts (offshore voluntary disclosure program, OVDP), report of foreign bank & financial accounts (FBAR), foreign account tax compliance act (FATCA), tax preparation, tax planning,  tax audit IRS representation, and the US treasury office of foreign assets control (OFAC),  contact Zaher Fallahi,  Los Angeles Tax Attorney, Los Angeles OFAC Attorney, Los Angeles Tax CPA, Los Angeles Dental CPA,  at (310) 719-1040 and Orange County Tax Attorney, Orange County OFAC Attorney, Orange County Tax CPA, Orange County Dental CPA, at (714) 546-4272 (Orange County) or e-mail: taxattorney@zfcpa.com

Mr. Fallahi has been an exceptional attorney throughout my experience with him. His deep expertise and thorough understanding of OFAC law were evident. He provided clear and insightful guidance that was crucial in my case. Mr. Fallahi's professionalism and commitment to me as his client were truly commendable. He consistently ensured my concerns were addressed promptly and effectively. I highly recommend Mr. Fallahi to anyone seeking expert advice and representation in OFAC matters.
It's been an honor to know Zaher Fallahi, Esq for the past 49 years.He is one of kind in almost everything. His clients and friends are always his priority. In my long life, I have had the chance to be helped by many people. But ZaherFalahi is a distinguished personality that his professionalism helped me to succeed in life.And that's why I never hesitate to refer my family and friends for all their legal and financial matters to him.
I have had the pleasure of knowing attorney Zaher Fallahi for over 10 years in a professional capacity. Zaher is knowledgeable, diligent, capable and a conscientious attorney. Zaher has a strong reputation in his field - International Tax and Undisclosed Foreign Bank Accounts - and is a good person, in general. I highly recommend him for your legal needs.
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