The US House of Representatives is expected to vote on a broadly supported bill this week that is designed to limit IRS ability to seize your bank account and freeze assets. The constitutional power given to the IRS to aid in the collection of unpaid taxes is known as "Civil...
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IRS Audits Focused on Small Businesses with Questionable Tactics
According to recently released information, the news source noted a significant increase in IRS audits focused on small businesses targeting $200,000 to $400,000 income rages. The IRS has been accused of some very questionable tactics as they attempt to gather information to show that small businesses are under-reporting income, especially income...
Why Should a Foreign National Working or Residing in the US Care about FBAR Compliance
Why should a foreign national working or residing in the US care about IRS FBAR compliance? "None of my friends or associates are aware of this or worried about it..." is a sentiment we often hear. Unfortunately, the IRS isn't interested in what a foreign national working or residing in...
The IRS Statute of Limitations on Collections Can Be Longer than 10 Years
What is a "statute of limitations" and how does it apply to debts you to the IRS? If you are a target of IRS collections, how long does the IRS have to collect a valid tax debt? Is it possible for the IRS statute of limitations on collections to be...
Appeal of FBAR Willful Violation Civil Penalty to 5th Circuit
In a technical legal move Bernhard Gubser, a dual US / Swiss citizen, asked the 5th Circuit Court to hear an appeal of his case against the IRS regarding a $1.4 Million FBAR willful violation civil penalty case which was tossed out by a lower court earlier this year. Mr....
IRS to Target Income from UBER, AIRBnB and other Sharing Income Sources
What would cause the IRS to target income from Uber, AIRBnB and other sharing forms of income? American University in Washington D. C. published a recent study that notes 2.5 million Americans earn income from Etsy, Uber, AIRBnB and other sources of "sharing" that presently go unreported. The IRS realizes...
What Impact will IRS Impeachment Hearings Have on San Diego IRS Audits?
There is considerable energy on capital hill to impeach the commissioner of the Internal Revenue Service (IRS) John Koskinen. Mr. Koskinen was brought in to replace Daniel Werfel after he and a subordinate, Lois Lerner, were forced resign after substantiated allegations that the IRS had inappropriately targeted members and organizations associated...
Transfer Pricing and International Business Issues
San Diego companies serving global markets often face transfer pricing and international business issues that increase risk and contingent liability. The international business and tax attorneys at Allen Barron have extensive expertise and experience in multiple aspects of international business. We are uniquely positioned to provide single-source service for those...
Lawsuit against IRS Offshore Tax Programs Dismissed
Another lawsuit challenging the IRS offshore tax programs has been dismissed. In the consolidated lawsuit, 3 plaintiffs attempted to assert that they should be able to switch to the IRS' streamlined domestic offshore procedures, which were not available when the 3 filed applications under the OVDP or Offshore Voluntary Disclosure...