Californians represent the largest portion of those with unreported Swiss financial accounts, and anyone with unreported foreign assets or accounts needs an experienced tax attorney, not simply a CPA. Why? The primary reason is: attorney-client privilege. As both an experienced tax attorney and CPA I can tell you the protections of attorney-client privilege for you as a client are much stronger and durable. If I am representing a client as a CPA, the IRS can compel any information in my possession or notes – information that can be used against the client. As your tax attorney, attorney-client privilege allows you to freely disclose and discuss all of the foreign assets in question so that we can have a thorough analysis and conversation about the impact of unreported account and/or assets, and prepare strategies to minimize the financial penalties while shielding you from exposure to criminal charges when possible.
The deadline for filing the IRS required Foreign Bank Account Report or FBAR is now virtually a month away. July 1 the IRS will have access to financial records, account data and property information from many foreign nations that it has not previously been able to uncover. The time to act is now. Many Californians have simply not reported accounts and assets in countries where they thought their information was secret and safe from the IRS. July 1st that will all change. Accurate 2014 FBARs must be presented. It may be imperative to file ammended FBARs for as far back as 8 years, which is the present statute of limitations for the IRS. As a tax attorney and CPA I can help you to take advantage of extensive tax and accounting expertise, while the attorney-client privilege protects as much of your assets as possible. Our work together will reduce the financial penalties you face, while restructuring your financial strategies to put you in the best possible position moving forward.