FBAR ALERT: IRS OVDP Ends in 18 Days

FBAR ALERT: IRS OVDP Ends in 18 Days

The IRS OVDP ends in 18 days as the IRS ramps up to pursue tax evaders.  For all US taxpayers with unreported offshore bank accounts, deposits, investment accounts, real estate and other assets this important deadline is fast approaching.  The consequences for failure to comply with US tax laws will be severe. If you have […]

September 28 is the Deadline for US Taxpayers with Offshore Accounts

September 28 is the deadline for US taxpayers with offshore accounts to come into compliance with IRS FBAR reporting requirements through the Offshore Voluntary Disclosure Program or OVDP.  US taxpayers who have yet to declare offshore bank accounts, investment accounts and assets have just over 3 weeks to declare these to the IRS or face […]

Manafort Conviction Includes Failure to File an FBAR

The news today that the Manafort conviction includes failure to file an FBAR is an example of two crucial IRS principles: willful blindness is no excuse under the law, and, the IRS will always use the failure to file an FBAR against US taxpayers.  The IRS concept of “willful blindness” addresses a standard US taxpayer […]

Business Disputes Require Experience and Negotiation Skill

Business disputes require experience and negotiation skill to ensure the best possible outcome.  Allen Barron’s skilled dispute resolution team resolve business disputes while accomplishing your goals. The fact is most business disputes are resolved by our skilled attorneys through negotiation.  This is based upon several important factors: business realities time expense contingent liability Business realities […]

IRS Partnership Audit Process Continues to Develop

The IRS partnership audit process continues to develop.  The “centralized audit regime” fundamentally changed the way the IRS audited partnerships.  On August 9 of this year the IRS released final regulations regarding naming the partnership representative, as well as the process to remove or replace this designated representative for all IRS tax matters. The final […]

Many In San Diego Will Pay More Taxes This Year

Recent tax reforms are not going to bring tax cuts for many typical households across California.  Many in San Diego will pay more taxes this year as the majority of deductions and write-offs of the past have been eliminated.  A recent article in the Sacramento Bee noted “about 751,000 households with incomes under $250,000 probably […]

Do You Have Too Many PALs?

Do you have too many PALs or “Passive Activity Losses” due to investments or real estate?  The challenge with Passive Activity Losses is they must be used to offset Passive Income Generators or PIGs.  The strategic use of PIGs and PALs is going to be crucial for many San Diegans under the new tax system. […]

Failure to File FBARs is a Key Issue in the Manafort Trial

The failure to file FBARs is a key issue in the Manafort trial and ultimately the charges he faces regrading tax evasion.  One of the witnesses called upon was Paula Liss, a certified fraud examiner, anti-money laundering specialist, and senior agent for the Treasury Department’s Financial Crimes Enforcement Network or FinCEN.  The Report of Foreign Bank […]

A Notification of Audit from the IRS is Serious Business in 2018

While the number of audits conducted by the IRS has dropped in recent years, the agency is focusing its resources on audit targets which will produce revenue for the US Treasury.  This is why a notification of audit from the IRS is serious business in 2018.  If you have been contacted by the IRS it […]

Pursuing Violations of Fiduciary Duty in San Diego

Are you looking for an experienced legal and financial team with experience pursuing violations of fiduciary duty in San Diego?  Many executives, board members and officers have the obligation to act in the best interest of the company or corporation known as a “fiduciary duty.”  The fiduciary duty exists when a special degree of expertise, […]

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