Tax Attorney Michael K. Miller is Quoted in Palm Beach Daily News

PALM BEACH, Fla. - May 14, 2013 - PRLog -- Palm Beach, Florida – Attorney Michael K. Miller is a tax attorney in Palm Beach, Florida. On Sunday, April 28th, 2013 the Palm Beach Daily News published an article entitled, “Foreign Accounts Under Scrutiny.” In this article, attorney Miller provided a wealth of insight into the current IRS offshore voluntary disclosure amnesty program and the newly-effective Foreign Account Tax Compliance Act of 2010, both of which are aimed at identifying U.S. tax evaders who have unreported offshore financial accounts; he gave suggestions on what people can do to minimize their exposure to civil and criminal sanctions relating to the  recent U.S. crackdown on offshore tax evasion.

The article opens with attorney Michael K. Miller stating that if you have a foreign bank account, beware that many foreign financial institutions are closing the accounts of their U.S.-based customers and requesting instructions as to where to transfer the funds in the account. Miller says that if you repatriate the funds to the United States, the IRS will likely be notified of the new deposit and may inquire as to the source of these newly-deposited funds.  If you have failed to report the offshore account and the income therefrom on timely-filed U.S. tax returns in prior years, you could face criminal prosecution (including possible incarceration) as well as significant income tax assessments and civil penalties.

According to Miller, the heat is on because of the recently-enacted Foreign Account Tax Compliance Act of 2010, which is designed to prevent U.S. persons from hiding income and assets overseas and most provisions of which take effect this year. Under the Act, foreign banks are strongly encouraged to start sharing information on their U.S. account holders with the United States on an annual basis, otherwise face a 30% withholding tax on certain U.S. source payments due to the foreign bank.

The United States is engaged in talks with 50 countries to further implement the Act, and it has already announced international tax compliance agreements with France, the United Kingdom, Germany, Italy, Norway, Ireland, Mexico, Denmark and Switzerland.

Miller says that the majority of his calls have been from customers who have their money in Swiss bank accounts. For many of these banks, instead of incurring significant annual costs in gathering the required information on its U.S. account holders and otherwise complying with the Act, they are opting to close accounts of U.S. customers and terminate these banking relationships. In the Palm Beach Daily News article, Miller said those with unreported offshore bank accounts basically have four options: 1) do nothing and hope the problem goes away (which no one recommends), 2) quietly amend your prior-year tax returns to report the previously-omitted offshore income and hope the IRS cashes the check for the additional taxes with no inquiry, 3) start reporting your foreign accounts/income annually going forward and hope the IRS accepts these returns without any questions about prior tax reporting for the offshore accounts/income, or 4) join the current IRS offshore voluntary disclosure amnesty program, which could be closed at any time. Under this amnesty program you can avoid criminal prosecution and qualify for reduced civil penalties.

According to attorney Miller, most people are choosing to join the IRS offshore voluntary disclosure amnesty program. He added that one can get pre-clearance from the IRS to make a voluntary disclosure under this program so as to be assured that he or she is eligible to enter the amnesty program before giving the IRS potentially-incriminating  information about their unreported offshore bank accounts. He also said that it usually takes about two days to get pre-clearance from the IRS.

Michael K. Miller has more than 20 years of experience in accounting and corporate and tax law. Prior to entering the legal profession in 1989, attorney Miller practiced as a Certified Public Accountant. During this time he served as a Revenue Agent (IRS Field Auditor) for the Internal Revenue Service in Washington, D.C., where he performed audits of individual income tax returns and enforced U.S. income tax laws and regulations. Attorney Miller received his initial formal legal training at the top-tier international law firm of Cadwalader, Wickersham & Taft, where he practiced tax and corporate law and engaged in domestic and international tax matters. Immediately prior to opening his own firm, he was General Counsel and Secretary of Dycon Industries, Inc., a NYSE-listed company with more than 8,000 employees and annual revenue exceeding $1 billion.

Attorney Miller is AV® Preeminent™ rated by Martindale-Hubbell®, one of the nation’s most respected attorney rating services, with the AV® distinction being the highest rating given to an attorney for ethical conduct and professional ability. Today, attorney Miller handles a wide variety of tax matters, including but not limited to offshore voluntary disclosure, tax resolution, tax audits, criminal tax defense, appeals, trust fund recovery penalty,offer in compromise, innocent spouse relief, tax liens & levies, and much more. To fully address your tax issue and obtain answers to your questions, contact The Law Offices of Michael K. Miller, P.A. by calling (866) 316-2238 or by visiting the firm’s website online at http://www.palmbeachcountytaxattorney.com.