In a technical legal move Bernhard Gubser, a dual US / Swiss citizen, asked the 5th Circuit Court to hear an appeal of his case against the IRS regarding a $1.4 Million FBAR willful violation civil penalty case which was tossed out by a lower court earlier this year. Mr....
IRS to Target Income from UBER, AIRBnB and other Sharing Income Sources
What would cause the IRS to target income from Uber, AIRBnB and other sharing forms of income? American University in Washington D. C. published a recent study that notes 2.5 million Americans earn income from Etsy, Uber, AIRBnB and other sources of "sharing" that presently go unreported. The IRS realizes...
What Impact will IRS Impeachment Hearings Have on San Diego IRS Audits?
There is considerable energy on capital hill to impeach the commissioner of the Internal Revenue Service (IRS) John Koskinen. Mr. Koskinen was brought in to replace Daniel Werfel after he and a subordinate, Lois Lerner, were forced resign after substantiated allegations that the IRS had inappropriately targeted members and organizations associated...
Transfer Pricing and International Business Issues
San Diego companies serving global markets often face transfer pricing and international business issues that increase risk and contingent liability. The international business and tax attorneys at Allen Barron have extensive expertise and experience in multiple aspects of international business. We are uniquely positioned to provide single-source service for those...
Lawsuit against IRS Offshore Tax Programs Dismissed
Another lawsuit challenging the IRS offshore tax programs has been dismissed. In the consolidated lawsuit, 3 plaintiffs attempted to assert that they should be able to switch to the IRS' streamlined domestic offshore procedures, which were not available when the 3 filed applications under the OVDP or Offshore Voluntary Disclosure...
Can the IRS Take Your Passport for Unpaid Taxes
When can the IRS take your passport for unpaid taxes, and does that prevent you from international travel? Yes, the IRS has the power to take many actions to collect unpaid US taxes including the ability to take away your passport. At present, you must owe the IRS $50,000 or...
Willful or Non-Willful Attempt to Avoid US Taxes?
There continues to be confusion regarding what constitutes a willful or non-willful attempt to avoid US taxes as it relates to offshore bank accounts, investments, assets and income. The IRS has purposefully failed to clarify this issue over the past 7 years. This is the first piece of evidence a...