By Janathan L. Allen, APC of Janathan L. Allen, APC posted in IRS on Monday, January 19, 2015. IRS Commissioner John Koskinen sent an internal email warning of poor and "unacceptable" customer service, as well as longer refund timeframes this year. The agency is blaming the poor performance on budget...
Wall Street Journal Notes US Expats Suing Canada for Agreeing to Provide Data About Their Accounts to the United States
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Tuesday, September 2, 2014. The Wall Street Journal documented a lawsuit filed against the Canadian government by a group representing US expatriates a few weeks ago challenging the "constitutionality" of the agreement reached between the US...
Transfer Pricing is one of the Highest Audit Risks for Multi-National Businesses in San Diego and Southern California
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in Business & Contracts on Friday, September 26, 2014. If you own or control a multi-national corporation it is important that you entrust an experienced and seasoned tax attorney with the task of evaluating your transfer pricing and the...
How Will Information Obtained by the IRS from Foreign Banks Trigger Audits for San Diego and Southern California Taxpayers?
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Sunday, September 28, 2014. The IRS recently obtained a windfall (from the IRS' perspective) of financial information relating to foreign accounts and assets specifically tied to US taxpayers or entities. Pressure brought upon foreign institutions by...
New OVDP Streamlined Domestic Offshore Procedures Do Not Provide Civil or Criminal Protection
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Friday, July 18, 2014. The recent release of the OVDP Streamlined Domestic Offshore Procedures (with a deadline of August 4th) was greeted with excitement in many quarters. Who wouldn't want to reduce penalties from 27.5% down...
Less Than One Month Remains To File Under the OVDP Streamlined Domestic Offshore Procedures
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Thursday, July 17, 2014. August 4 is the due date for those who wish to submit an application to the IRS under the Streamlined Domestic Offshore Procedures of the OVDP and avoid the increased foreign account...
Filing for OVDP Streamlined Domestic Offshore Procedures Could Reduce Your Penalty from 50% to 5% – a Large Sum for Any US Taxpayer
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Friday, July 4, 2014. The new Streamlined Domestic Offshore Procedures within OVDP represent a tremendous opportunity for any US taxpayer with foreign accounts and assets to come into compliance with the IRS, and reduce their penalties...
New rights proposed for taxpayers under new bill
On behalf of Janathan L. Allen, APC posted in Back Taxes or Tax Debt on Thursday, June 25, 2015. So much of what we write here on this blog may make taxpayers feel insignificant and powerless when they are facing the IRS. Taxes are complicated and very, very important --...
IRS Adds More Swiss Banks to Automatic 50% OVDP Penalty List
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Tuesday, June 9, 2015. The IRS has added severl new Swiss banks to the list of institutions that carry a mandatory 50% penalty instead of the 27.5% penalty provided in most OVDP filings. It doesn't matter...