On behalf of Janathan L. Allen, APC posted in Management Advisory Services on Monday, July 2, 2012. When an existing or new client (or most importantly, a potential client) calls in or visits your office, what is their first impression of your business? First impressions matter! Businesses big and small...
IRS may be overwhelmed this tax season
On behalf of Janathan L. Allen, APC posted in IRS on Wednesday, January 14, 2015. In a very interesting report published by the Federal Advocate for Taxpayers, there are some serious accusations that the Internal Revenue Service may not be able to respond adequately -- or at all -- to...
IRS Commissioner Warns of Poor Customer Service and Slower Refunds in 2015
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...