On behalf of Janathan L. Allen, APC posted in IRS on Thursday, July 24, 2014. Over the years, so much can change in a person's life. They may get a new job. They may move, within the city they already call home or to a completely different state, or even...
IRS: Who Determines Willful or Non-Willful Conduct for Offshore Account and FBAR?
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Monday, July 7, 2014. The past few months have brought several historic and dramatic developments in respect to offshore financial reporting, the IRS, and questions of whether US taxpayers have shown "willful" or "non-willful" conduct as...
Americans are giving up citizenship as a result of FATCA
On behalf of Janathan L. Allen, APC posted in Tax Controversy on Thursday, July 10, 2014. We've written about the Foreign Account Tax Compliance Act (FATCA) extensively on this blog, and with good reason. The U.S. law extends an expansive reach over foreign banks and compels these institutions to report...
What is FATCA and Why is July 1 So Important This Year?
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Tuesday, June 3, 2014. FATCA (The Foreign Account Tax Compliance Act) was passed in 2010, and requires all US citizens with foreign investment or banking accounts to report them to the IRS. FATCA also requires foreign...
US District Court Upholds Massive FBAR Pentalties Against 87 Year Old Florida Man
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Wednesday, June 18, 2014. I've been shouting from the proverbial rooftop for the past several months, and a recent decision by the US District Court is an example of why: an 87 year old man has...
Taxes and retirement: how to set yourself up for the later years
On behalf of Janathan L. Allen, APC posted in Tax Controversy on Wednesday, June 11, 2014. Imagine you are approaching your retirement. After years and years of work and saving, you've finally reached the point in your life where you can leave the workforce behind and enjoy your remaining years...
Which IRS Program is Best for Those Who Have Issues with FBARs?
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Monday, December 29, 2014. The IRS has two main options for those who have either under-reported or failed to report foreign accounts or assets on the FBARs associated with their returns. The first option is the...
When Are Tax Returns Confidential And Privileged From Production? (Part 2)
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in California Tax on Thursday, December 11, 2014. Company Protected Against Forced Disclosure of Tax Returns In Casa W LLC v. Superior Court of Los Angeles County et al., Kyle Madison, his former wife Marjan Madison, and their friend...
When Are Tax Returns Confidential And Privileged From Production? (Part 1)
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in IRS on Wednesday, December 10, 2014. California is one of the few states that holds tax returns may be privileged and not subject to discovery during civil litigation, except under certain circumstances. The privilege applies to both state...