LOS ANGELES, April 04, 2016 (GLOBE NEWSWIRE) — Last anniversary afterwards about a year of waiting, the Brager Tax Law Group accustomed IRS abstracts afterwards filing a Freedom of Information Act (FOIA) Appeal in aboriginal April 2015.
The appeal stemmed from a chat that a Brager Tax Law advocate had with the IRS’ Offshore Voluntary Disclosure Program (OVDP) hotline to ask about the analysis of a Superannuation account. Superannuation accounts are the Australian adaptation of the U.S. tax-favored retirement plans. These accounts, sometimes referred to as Supers, can be actual ambiguous for immigrants from Australia to the U.S., because they may or may not be accountable to taxation in the U.S. The buying of a Super may activate the claim to book an FBAR (Foreign Bank Annual Report, FinCEN Form 114, aforetime TDF 90-22.1) and/or Form 8938, Form 3520 or Form 3520-A.
“The able analysis of a Super beneath U.S. tax law is confusing, because there are altered types of Supers,” according to Dennis Brager, architect of the Brager Tax Law Group, “and, depending aloft the facts and circumstances, the U.S. tax analysis may differ.”
Brager describes the chat with the IRS. “We were told that no Form 3520 was required. The being we batten to was acutely annual from a calligraphy and, of course, we asked for a copy. Just as predictably, we were told that it was an ‘internal document,’ and, therefore, we couldn’t get it.” Brager filed the FOIA Appeal and waited…for 11 months.
The FOIA appeal appear a alternation of emails amid assorted abstruse specialists in the IRS’ Offshore Compliance Group, IPN OVDP Coordinator. “These emails announce that at atomic through aboriginal 2015 some IRS personnel, including those who were apparently in the best position to accept the intricacies of adopted retirement affairs still had abounding questions,” says Brager. “Because the emails are redacted, it is difficult to acquaint absolutely who was in the dark. The emails may abutment an altercation that there was reasonable annual for any abortion to address income, book FBARs or book Forms 8938 accompanying to adopted retirement affairs including Australian Superannuation accounts.”
Brager continues, “As backward as the end of November 2014, whether an Australian Superannuation annual was a adopted banking annual reportable on an FBAR was still a affair of discussion! The email is additionally absolute in that it seems to reflect a mindset to attack the access of the bulk of the OVDP penalty.”
The abstracts acquired by the Brager Tax Law Group from the IRS beneath the FOIA are on the Brager Tax Law Group website at www.BragerTaxLaw.com. This was the additional FOIA appeal filed by Brager aural 13 months. “We will abide to book FOIA requests back the IRS can’t acknowledgment questions to our satisfaction,” Brager concludes. “But it’s adverse that the IRS needs 11 months to aftermath these abstracts that are analytical for taxpayers and tax preparers to accept and accede with our circuitous tax system.”
Based in Los Angeles with a common applicant base, the Brager Tax Law Group is a tax action and tax altercation law firm, which represents audience with tax disputes with the IRS in all 50 states, the California Franchise Tax Board (FTB), the State Board of Equalization (SBE) and the Employment Development Department (EDD). All of the Brager Tax Law Group’s tax attorneys are above balloon attorneys with the IRS.
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