By Janathan L. Allen, APC of Janathan L. Allen, APC posted in Audits on Monday, June 22, 2015. The IRS has tremendous powers when it comes to the collection of back tax debt. The standard limitations The IRS usually has 10 years from the point an "assessment" is made to...
IRS Shortening Taxpayer Response Times in Audits?
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in Audits on Friday, June 19, 2015. A recent report out of South Dakota asserted that the IRS has shortened the amount of time it allows US taxpayers for responding to requests from the IRS during an audit. The...
Judge Agrees to Hearing in IRS verus Microsoft Case
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in IRS on Thursday, June 18, 2015. Microsoft has challenged the IRS' authority to bring in a private, outside attorney to advise the agency on their deep and complex audit of Microsoft. The central question involves the ability of...
Here are 5 non-U.S. banks newly added to the IRS’s 50 percent penalty list
On behalf of Janathan L. Allen, APC posted in FATCA on Wednesday, June 17, 2015. The list is long and getting longer. The IRS recently added five more banks to the list of non-U.S. banks where, if you're an American, your account triggers an automatic 50 percent FBAR penalty based...
Many Swiss Banks are an Automatic 50% FBAR Penalty
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Monday, June 15, 2015. The IRS has generated a list of banks, many of whom are Swiss, who have participated in actively helping US taxpayers to shelter money and income from the IRS. If you have...
Do you have Swiss Accounts in Rothschild Bank AG or Banca Credinvest SA?
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Friday, June 12, 2015. San Diego and southern California residents with accounts in Rothschild Bank AG or Banca Credinvest SA should know that both Swiss banks recently entered into agreements with the US Department of Justice...
FATCA and the IRS FBAR Have US Taxpayers and Foreign Banks in a Perfect Crossfire
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Thursday, June 11, 2015. The US Department of Justice (DOJ) and the IRS have worked for the past several years to establish the perfect crossfire scenario: foreign banks and US citizens forced to provide information on...
IRS Updates FBAR Penalty Guidelines and Willful Conduct Parameters
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Wednesday, June 10, 2015. There has been a lot of confusion over what will constitute "willful" versus "non-willful" conduct in terms of FBAR reporting of foreign bank acounts and associated penalties for under-reporting them. The IRS...
Appeals court undercuts California regulator in tax dispute
On behalf of Janathan L. Allen, APC posted in Tax Controversy on Friday, June 5, 2015. Part of California's tax policy has been ruled unconstitutional. The decision is being seen by some as a win for out-of-state businesses and, more specifically, individuals who might be interested in buying Harley-Davidson motorcycles...