By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Wednesday, June 10, 2015. There has been a lot of confusion over what will constitute "willful" versus "non-willful" conduct in terms of FBAR reporting of foreign bank acounts and associated penalties for under-reporting them. The IRS...
Appeals court undercuts California regulator in tax dispute
On behalf of Janathan L. Allen, APC posted in Tax Controversy on Friday, June 5, 2015. Part of California's tax policy has been ruled unconstitutional. The decision is being seen by some as a win for out-of-state businesses and, more specifically, individuals who might be interested in buying Harley-Davidson motorcycles...
Yes, Failure to Report Foreign Bank Accounts Can Lead to Jail
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Wednesday, June 3, 2015. Do you really need to be concerned with how you submit your application to the Offshore Voluntary Disclosure Program (OVDP) or the streamlined option within it? The IRS will simply accept a...
Is Your Foreign Bank on the IRS List of Banks that Trigger a 50% OVDP Penalty?
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Tuesday, June 2, 2015. The IRS maintains a list of international banks that trigger an automatic 50% Offshore Voluntary Disclosure Program (OVDP) penalty instead of the standard 27.5% for those that file under the program. The...
IRS Under Fire for Using External Firm for Audit of Microsofts Offshore Investment Activities
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in Audits on Monday, June 1, 2015. The IRS is taking substantial heat from the US Senate regarding its decision to hire an outside law firm to assist with an investigation into Microsoft's alleged activities to shift profits offshore...
US Expats Affected by New Saudi Arabian Law Arising out of FATCA
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Friday, May 29, 2015. The Foreign Accounts Tax Compliance Act or FATCA continues to have far reaching implications for US Expatriates, even affecting laws outside of the United States. Saudi Arabia recently announced and will soon...
The IRS “Speed Up” Audit Tactics Can Harm US Taxpayers
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in Audits on Wednesday, May 27, 2015. Recent budget cuts and substantial new congressional regulations have resulted in a new tactic by the IRS: the "Speed Up" audit. The IRS has limited resources and is pushing them to complete...
What FATCA is and why its scope is unprecedented
On behalf of Janathan L. Allen, APC posted in Tax Controversy on Tuesday, May 26, 2015. The Foreign Account Tax Compliance Act, or FATCA, is a tax rule that was enacted by the United States in 2010. What the rule does is compel other countries to disclose financial information of...
How is FATCA Affecting Worldwide Banking and Tax Change?
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in Audits on Monday, May 25, 2015. The US Foreign Account Tax Compliance Act, or FATCA, has wrought significant and I believe historical change in the transparency of international banking and resulting US taxation. With the capitulation of Union...