A recent court decision may provide taxpayers relief and protection from IRS collection of FBAR penalties based upon a 3 year statute of limitations. The US Tax Court has issued its first decision of 2018 which considered whether FBAR related collections by the IRS could go back six years. The...
Ignorance of IRS FBAR Reporting is Not a Defense
Our offices have handled many cases recently of foreign nationals and spouses with offshore accounts and assets who were not aware of their IRS FBAR reporting requirements. Unfortunately ignorance of IRS FBAR reporting is not a defense and the IRS is ruthlessly pursuing huge penalties and interest for those who...
Strong and Experienced Legal Counsel for San Diego Businesses
Allen Barron provides strong and experienced legal counsel for San Diego businesses and business owners. Our unique integrated service offering provides a one-stop source for any business related matter. The integrated legal, tax, accounting, estate planning and business advisory services ensure you receive a complete answer to your questions, opportunities and challenges...
Taxation of Pass Through Income Versus Salaried Earnings
There is a lot of confusion surrounding the taxation of pass through income versus salaried earnings as US taxpayers assess their positions after tax reform. This is far from "finished" and a wild roller-coaster ride is about to ensue for many US taxpayers. How will you know what to do? ...
IRS and Bitcoin – Do Crypto Currencies Need to be Reported on the FBAR
The IRS believes that virtual currencies such have Bitcoin have become a tool in tax evasion, and the agency is signalling more enforcement actions and IRS audits in the coming months. The real question many crypto currency investors must consider is do crypto currencies need to be reported on the...
The 20 Percent Deduction for Pass Through Income
The tax bill presented for the President's signature contains the 20 Percent Deduction for pass through income for the majority of US partnerships, S Corporations and sole proprietorships. Under existing tax law, business profits were passed through to the individual and taxed at their personal income rate. The top individual...
New Tax Plan Presents Challenges for IRS Auditors
The new tax plan presents challenges for IRS auditors as we all await the final draft of tax reform legislation in Washington. The primary concern centers around the ability of wealthy US taxpayers to "reap massive windfalls" by simply reclassifying income as "pass-through business income." The most recent "final" plan...
New Integrated Legal Tax Accounting and Business Advisory Services White Paper
Allen Barron has recently published a new integrated legal tax accounting and business advisory services white paper detailing the issues business owners, executives, officers and directors face going forward in 2018 and how integrated services provide greater insight into today's business challenges and opportunities. The new white paper "Allen Barron...
What are Willful Conduct and Willful Blindness in IRS FBAR Audits
What are willful conduct and willful blindness in IRS FBAR audits and court cases? It is important to begin with an understanding regarding IRS FBARs and when they are required. Any US taxpayer who has offshore bank or investment accounts (outside the United States) is required to prepare and file an...