We have seen several recent examples of people who were convinced to set up international or foreign trusts in order to "shield income and assets" from needless taxation. No, these aren't foreign citizens with foreign interests, they are US taxpayers who have been convinced to open a foreign trust which...
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San Diego FBAR Attorneys Guide Offshore Compliance with IRS
If you have offshore accounts, investments or assets and have not come into compliance with the IRS, you should contact the San Diego FBAR attorneys at Allen Barron, who will provide guidance and insight into your options and help to ensure the best outcome in your case. Which voluntary disclosure...
The Difference Between an A-B Trust and a Disclaimer Trust in San Diego
What is the difference between an A-B trust and a disclaimer trust in San Diego? The classic A-B trust has been around for years. The A-B trust was developed for spouses, and places the property, investments, accounts and assets of a married couple into a revocable trust known as an...
US Justice Department Wins First FATCA Legal Victory – Shell Company and Its Nominees
Last week, the US Justice Department announced its first FATCA Legal Victory when it announced that Gregg R. Mulholland, owner of an offshore investment management company based out of Panama and Belize has plead guilty to money laundering and conspiracy. The firm was accused of fraudulent behavior, manipulating the value of...
700 New IRS Auditors to Target Small Business and Self Employed
The Wall Street Journal recently examined plans for 700 new IRS auditors who will be added to the IRS department that specifically monitors small business and the self-employed. IRS Commissioner John Koskinen claims the new money was found as a result of retirements, internal turnover, and other "efficiencies." Lawmakers are...
IRS Hires 700 New Auditors
The IRS hires 700 new auditors raising the ire of republican watchdogs and raising new questions about Commissioner John Koskinen's previous testimony regarding budget cuts and the need for an increase in the budget for the IRS. The Chairman of the House Oversight and Reform Committee responded sharply: "Now, less than...
IRS Wins Case Against Taxpayer Outed by Swiss Bank UBS Group Who Claimed “Innocent Error”
For all US taxpayers who have been watching developments in FATCA, FBAR reporting and the IRS Offshore Voluntary Disclosure Program or OVDP, last week's court case was striking in it's message: The IRS will not accept taxpayer claims of "innocent error" or related claims such as "ignorance to the law"...
Court Dismisses Case Against $1.4M IRS Offshore Penalty
A Texas court has dismissed a lawsuit against the IRS asserting that the IRS burden of proof to assess a $1.4M IRS offshore penalty had not been met. The IRS originally asserted that the plaintiff's failure to file an FBAR for his offshore accounts, assets and investments in 2008 was...
Prince’s Lack of a Will Highlights the Value of a Trust
The death of the artist Prince was a shock to many of us. What surprised me as a trust, estate and tax attorney is his complete abdication of planning his estate, especially when you consider the energy and effort he expended to protect his music and the rights to it....