By Janathan L. Allen, APC of Janathan L. Allen, APC posted in IRS on Monday, August 4, 2014. Higher penalties await those who have not successfully filed under the OVDP or the IRS Streamlined Domestic Offshore Procedures. Today, August 4, the IRS will move forward with plans to pursue higher...
If You Have an Ownership Interest in a Business That is Being Sold You Should Have Your Own Attorney
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in Mergers & Acquisitions on Friday, August 8, 2014. We have extensive experience representing individuals who have an interest in the sale of a business, and the good news is that most or all of our fees will be...
Why Is This Any Different for the IRS and FBARs and Foreign Accounts than at Any Time in History?
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Saturday, July 5, 2014. The IRS has gained access to the vast majority of offshore account and property information. This data ties those accounts and assets to specific US social security numbers and Federal Taxpayer IDs,...
If You Have (or Should Have) Filed an FBAR with the IRS over the Past 8 Years You Need to Read This
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Monday, June 30, 2014. If you have filed an FBAR with the IRS over the past 8 years, or had any foreign asset or account in that period and did not fully disclose it to the...
How Did the IRS Find Out About My Swiss Accounts and Foreign Assets?
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Friday, June 13, 2014. The shortest and most relevant answer to the question of how the IRS discovered almost $2 Trillion in hidden assets in offshore accounts and property is FATCA. The US Justice Department pursued...
How Can You Reduce Penalties for Under-Reporting FBAR or Foreign Accounting with IRS from 27.5% to 5%?
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Wednesday, June 25, 2014. The good news is that the IRS has released new streamlined guidelines for the OVDP that provide an opportunity for resident US taxpayers to reduce penalties for non-reported or under-reporting on the...
U.S. Expatriates Should Read IRS Publication 54 – Tax Guide for U.S. Citizens and Resident Aliens Abroad
U.S. expatriates should read IRS Publication 54 - Tax Guide for U.S. Citizens and Resident Aliens Abroad. This is a beneficial article published by the agency itself, detailing the unique and specific tax reporting requirements and rules when reporting offshore or "foreign-earned" income to the Internal Revenue Service. 3 Important...
If You Have Any Property or Assets Offshore Then June 30 is a Date You Should Have Circled in Red
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Monday, May 12, 2014. June 30 is an important deadline for any US citizen or foreign national working in the US that has any real property, assets or financial accounts outside of the United States. You...
California Swiss Account Holders Will Be Required to Update FBARs with Previously Undisclosed Account Data
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in IRS on Friday, May 16, 2014. Californians who have previously not reported assets and accounts they had secreted in Swiss institutions will be required to file amended Foreign Bank Account Reports, or FBARs with the IRS. The deadline...

