I Didn’t Know I needed to File an FBAR – Is That Non-Willful Conduct?

I hear it often - from dinner parties to fellow travelers to those who simply call for advice: "I didn't know I needed...

Improving offshore reporting and FBAR compliacne associated with foreign bank accounts, investments and income remains a top priority for the IRS according...

There will be no extension to the June 30 FBAR filing deadline for US taxpayers who are required to file an IRS...

The IRS has made significant changes to the forms associated with the Streamlined Domestic Offshore Procedures, a voluntary disclosure to the US...

The IRS reports that it is receiving a vast amount of offshore account information from foreign banks, investment institutions and sovereign tax...

Is it possible that a trust established under the laws of a US State such as California, with a US agent serving...

Why has the IRS questioned or outright rejected many of the applications under the Streamlined Domestic Offshore procedures?  How has the IRS...

There are very few safe tax havens left in the world, and the vast majority of the Swiss financial houses, banks and investment...

IRS FBAR compliance ensures you disclose all information about offshore accounts, assets, balances and transactions before the IRS comes knocking on your...

There is a lot about "disregarded entities" in the news recently due to a new ruling by the IRS in conjunction with...

One thing is clear about the massive release of additional documents in the "Panama Papers" scandal yesterday: It's only a matter of...

A Texas court has dismissed a lawsuit against the IRS asserting that the IRS burden of proof to assess a $1.4M IRS...

For all US taxpayers who have been watching developments in FATCA, FBAR reporting and the IRS Offshore Voluntary Disclosure Program or OVDP,...

Last week, the US Justice Department announced its first FATCA Legal Victory when it announced that Gregg R. Mulholland, owner of an offshore...

If you have offshore accounts, investments or assets and have not come into compliance with the IRS, you should contact the San...

Don't be distracted by the US House of Representatives hearings where they are attempting to impeach IRS Commissioner John Koskinen.  The commissioner...

FATCA has completely changed the international financial landscape - from FBAR crackdowns to the "Panama Papers."  Recently, many people have asked "Is...

The IRS Offshore Audits Have Begun The IRS has begun the first round of offshore income, asset and bank account reporting audits,...

If you are a US expatriate or a taxpayer with offshore accounts, investments, assets or income you should be aware your IRS FBAR...

If you had a financial interest in a foreign financial account, or signatory or authority over one or more accounts whose aggregate...

It's official.  The FBAR audit warnings and IRS data mining you've been reading about in this space for the past several years...

We are constantly being asked "Why do I have to worry about filing an FBAR in San Diego and what happens if...

The US Treasury Department and the IRS to propose changes to offshore business taxes and a practice known as "Inversion."  A hearing...

A leading IRS National Taxpayer Advocate has issued her mid-year findings for 2016 last week.  The report is very critical on the...

For those who are residing or working in the United States it is important to understand foreign nationals must meet FBAR compliance...

Foreign nationals who reside in the United States and those who are here working on an H1-B visa are required to report...

Are you a foreign national living or working in the United States?  Allen Barron has important tax information for foreign nationals in...

It is a bitter pill to swallow.  There are fewer and fewer secrets.  The world is becoming much smaller for tax evasion...

Our San Diego FBAR attorney helps foreign nationals comply with the IRS and fulfill offshore financial disclosures.  The penalties for US taxpayers...

Many foreign nationals come to the US each year, often under an H1-B visa, in order to live and work.  It is important...

Has the IRS decided to shut down the application process for the Streamlined Domestic Offshore Procedures under FBAR?  Streamlined applications for FBAR...

Citizens and former residents of India face genuine tax issues while they live and work in the United States.  Many Non-Resident Indians...

There continues to be confusion regarding what constitutes a willful or non-willful attempt to avoid US taxes as it relates to offshore...

In a technical legal move Bernhard Gubser, a dual US / Swiss citizen, asked the 5th Circuit Court to hear an appeal...

Why should a foreign national working or residing in the US care about IRS FBAR compliance?  "None of my friends or associates...

A storm is on the horizon for those who fail to report offshore financial activity to the IRS.  We are often asked...

Did you file an application under the IRS Streamlined Domestic (Foreign) Offshore Procedures?  What happens if the IRS rejects your FBAR streamlined...

We have advised foreign nationals living and working in the United States to come into compliance with IRS FBAR requirements for quite...

The world is an ever-changing ever-evolving crucible of financial challenges for US expats.  Many in the US have threatened to "leave the...

Have you come into the San Diego area on an H1-B visa in order to work in one of our high tech...

Earlier this year the IRS, with the help of a US Bankruptcy Judge, successfully pierced a complex strategy by two Texas brothers Sam and...

The IRS FBAR audits and prosecutions have begun and the clock is ticking for those who have yet to come into full...

This week John Koskinen, IRS Commissioner, claimed success based upon FATCA driven voluntary disclosures by US taxapayers.  The IRS disclosed more than...

Just when many thought the wave of IRS focus on offshore accounts and investments had passed the next wave has reached our...

The goal of financial transparency worldwide is gaining momentum.  The US FATCA initiative has spawned like legislation around the globe.  The benefit...

There are a lot of new acronyms in the world of international taxation.  What do CRS GATCA and the OECD have to...

The implementation of global forms of the US FATCA tax initiative, often referred to as GATCA (Global FATCA) continue to gain steam...

The University of Rochester has gained unexpected notoriety recently as one of it's professors faces sentencing in a criminal tax evasion scheme....

The penalties associated with non-compliance with the reporting of offshore accounts, assets and income to the IRS continue to escalate.  Many US...

The Organization for Economic Co-Operation and Development or OECD is comprised of 35 member nations including the United States, almost all of...

Why are there so many people who have used Turbo Tax and other home tax software solutions (including the free IRS version)...

The US 9th District Court here in California has found that willful failure to file FBAR is a lesser standard of proof...

The recent case this month in the US District Court sends a clear message to US taxpayers: Make a full, transparent voluntary FBAR...

Argentinas offshore amnesty program nets $5.2 Billion in taxes after Argentinians disclosed over $90 Billion in previously hidden assets.  Under the law...

The Israel Supreme Court ruled that US citizens in Israel must comply with FBAR and all IRS reporting requirements and the consequences...

The world is still unpacking the impact of FATCA and the IRS' intent to track offshore bank accounts, investments and corporations.  The...

The US Treasury Department published the latest list of those who renounced their US citizenship in 2016.  The recent spike in renounced...

It's been more than a year since the international "Panama Papers" scandal hit where 11.5 million documents disclosed the true owners of...

Just a reminder that your IRS FBAR reporting is due along with your tax return on April 18th this year.  The Foreign...

If you live or work in the United States it is your responsibility to understand tax laws.  This is why Allen Barron...

A Pennsylvania Court has denied motions by both parties to dismiss a high profile trial which may shed light on willful conduct...

On October 11, 2017 from noon to 2:00 pm pacific time, Jan Allen will speak on IRS FBAR and willfulness during a...

A new IRS Large Business & International (LB&I) campaign targets US taxpayers for IRS audits focused upon OVDP declines and withdrawls from...

A major US financial newspaper today echoed Allen Barron's repeated warnings to offshore account holders to fear the IRS and impending IRS...

What are the tax issues of working in San Diego on an H1-B Visa or living in the US as a foreign...

How does the IRS define willfulness in terms of IRS FBAR compliance?  When will the actions of a US taxpayer amount to...

What is the US tax impact of opening a foreign account for a US taxpayer including foreign nationals who live and work...

IRS FBAR audits are heating up as offshore banking and taxpayer information pours into the IRS from offshore banks, financial institutions, investment...

Recently released IRS FBAR reporting notes detailed some interesting facts regarding FBAR filings since the program's inception in 2007.  In 2007 the...

The IRS is closing in on US taxpayers with offshore accounts thanks to the global exchange of information which has been a...

There are still many US taxpayers who are in the process of understanding IRS FBAR compliance and the genuine risk their activities...

How can Allen Barron better protect you and your FBAR compliance issues with the IRS?  How can Allen Barron help you come...

The Sixth District of the US Court of Appeals upheld requirement for IRS FBAR reporting recently.  The decision affirmed the actions of...

We often hear clients say "The IRS will never know about my offshore financial accounts and assets," with conviction as if they...

Jan Allen speaks on a national IRS FBAR panel tomorrow at 12:30 pm pacific time, 3:30 pm eastern.  The topic of the...

What is willful blindness in IRS FBAR cases and how is the IRS attempting to use this to make non-willful FBAR violators...

A recent case in the United States District Court for the Eastern District of Pennsylvania has turned the recent tide of IRS...

While facing a slew of federal charges including conspiracy against the United States the FBAR related charges will put Paul Manafort behind...

The failure to comply with IRS FBAR reporting requirements was part of the recent Manafort indictment, but it doesn't just apply to...

Are you a foreign national living and working in San Diego?  Have you come into the US on an H1-B or other...

The US Court of Federal Claims found two US Canadian taxpayers fail to file FBARs resulting in summary judgment for the IRS. ...

What are willful conduct and willful blindness in IRS FBAR audits and court cases?  It is important to begin with an understanding...

The IRS believes that virtual currencies such have Bitcoin have become a tool in tax evasion, and the agency is signalling more...

Our offices have handled many cases recently of foreign nationals and spouses with offshore accounts and assets who were not aware of...

A recent court decision may provide taxpayers relief and protection from IRS collection of FBAR penalties based upon a 3 year statute...

If you have offshore bank accounts, investment accounts or assets you need to understand IRS FBAR requirements and your risks as a...

Is your investment in a cryptocurrency such as bitcoin triggering IRS FBAR reporting requirements for your tax return?  What are the potential...

If you are a US taxpayer, including foreign nationals who live and work in the United States you need to take notice. ...

As the IRS announces an end to Offshore Voluntary Disclosure programs associated with the reporting of offshore bank accounts, investments and assets,...

Is this the end of the OVDP for IRS FBAR disclosures regarding offshore bank accounts, investment accounts and assets?  The IRS has...

The IRS has been quite clear in recent publications that a "quiet" disclosure of offshore bank accounts and assets not previously reported...

Allen Barron provides extensive tax expertise and assistance with FBAR Preparation, Filing and Compliance.  If you have offshore bank accounts, investments, assets...

The Offshore voluntary disclosure program or OVDP is by far the safest way to come into compliance with offshore bank account, investment...

The IRS has added 7 more Swiss banks to the 50% OVDP Penalty List in December, and now more than 100 Swiss...

This is the last year that the Report of Foreign Bank and Financial Accounts, or FBAR, will be due to the IRS...

US taxpayers must be aware of the complications of offshore investment accounts as they relate to tax liability and the ramifications of...

What are the tax implications of offshore investments, bank accounts and foreign corporate ownership?  Allen Barron is uniquely positioned to provide expert...

The IRS continues to add more and more international banks, financial and investment firms to its list of 50% OVDP penalty institutions...

What are some of the tax implications of marrying a non-US citizen or permanent resident?  What are some of the hidden issues...

How Many US taxpayers still need to file offshore disclosures and FBARs with the IRS?  Should those who have not yet filed...

The IRS has reported that the number of "Report of Foreign Bank and Financial Reports" or FBARs filed in 2015 is up...

Yesterday, we discussed the rapidly rising number of “Report of Foreign Bank and Financial Reports” or FBARs filed in 2015.  This continues a...

What are the risks and penalties of not making a full offshore disclosure to the IRS?  What happens if you have not...

We have been at the forefront of the IRS crackdown on offshore bank accounts, foreign investments and corporate ownership and the requirement...

In the past few days, news of the "Panama Papers" has revealed more than 11 million documents which contain private offshore banking...