How does the IRS define willfulness in unreported or under-reported offshore income? What actions help determine whether a U.S. taxpayer's actions amount to "willful or non-willful" conduct? Why should U.S. taxpayers be concerned whether the IRS perceives their actions as willful? If you have accounts with any Foreign Financial Institutions...
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What to do if You Receive an IRS Audit Notification Letter
What should you do if you receive an IRS audit notification letter? Why should you consider engaging experienced IRS audit and tax attorney Janathan Allen, who represents U.S. taxpayers facing an IRS audit or any other federal or state tax issue. There are several things you should know if you...
Remarriage and a Blended Family – It’s Time for a New or Updated Estate Plan
Are you considering remarriage? Do you and/or your spouse have children from a previous marriage? If so, remarriage and a blended family are excellent reasons for a new or updated estate plan. Blended families are quickly becoming the "norm" here in San Diego and across the U.S. What do you...
You Sign Every Tax Return Under The Penalties of Perjury
Many Americans have not noticed the paragraph above their signature line on the 1040 and other IRS and state tax forms, which notifies the taxpayer that they signed their tax return "under the penalties of perjury" and that they had examined the return and underlying schedules. The "Sign Here" block...
Selling items Online? Is the IRS Watching?
Are you selling items online or receiving payment for goods and/or services on platforms such as PayPal, Venmo, eBay, Zelle, Etsy, or Cash App? Online platforms are the preferred method of shopping for most Americans. These platforms also support the gig economy and, what has to date been, the potential...
The Step Doctrine and How it Applies to IRS, State, and California Tax
It is important to understand the step doctrine and how it applies to IRS audits and state tax investigations, including California tax audits. The "step doctrine" is a concept not directly found in federal or California law, but that has been borne out of Court decisions since the great depression,...
Most Business Owners Undervalue Accounting
It's astonishing how many business owners undervalue accounting and its profound financial impact on business operations, transactions, taxation, and profit. An effective accounting strategy captures the information required to quickly and accurately identify potential business challenges and opportunities. Accurate accounting is the key to reducing tax exposure while providing critical...
What is the “Abusive Use of Partnerships” and Why does the IRS Care?
What is now considered as the “abusive use of partnerships,” and why would this matter to the IRS? The agency recently released IR-2024-166, which is intended to provide “new guidance to stop partnerships from using sophisticated tax-free transactions that lack economic substance” to avoid paying taxes. . The IRS continues to...
What is an FBAR and What Foreign Financial Information Are You Required to Report?
What is an FBAR, and what information is a U.S. taxpayer required to report to the U.S. Government and the IRS? There are many questions about the requirements for U.S. taxpayers with foreign accounts, investments, and assets, as well as the exchange of financial information between the IRS and Foreign...