The US Treasury Department and the IRS to propose changes to offshore business taxes and a practice known as "Inversion." A hearing yesterday brought stiff resistance from representatives in the business community and others seeking to preserve offshore tax advantages. "Inversion" is one of the specific strategies addressed in the...
The IRS has Begun Data Mining for Offshore FBAR Audit Targets
It's official. The FBAR audit warnings and IRS data mining you've been reading about in this space for the past several years have been confirmed by the Wall Street Journal (WSJ): U.S. Mining Swiss Bank Data to Find Tax Cheats It wasn't a question of "if" it was a question...
FBAR Electronic Filing Due June 30 – No Extensions
If you had a financial interest in a foreign financial account, or signatory or authority over one or more accounts whose aggregate value exceeded $10,000 USD at any point in 2015, you are required to file an IRS FBAR (Report of Foreign Bank and Financial Accounts). You must submit the FBAR...
IRS FBAR Submission is Due June 30 – Come Into FBAR Compliance
If you are a US expatriate or a taxpayer with offshore accounts, investments, assets or income you should be aware your IRS FBAR submission is due June 30 of this year. Starting next year, FBAR reporting will coincide with the normal IRS deadline of April 15. The FBAR or IRS Foreign Bank...
Once Contacted by the IRS – You Cannot File OVDP or other FBAR Compliance
The IRS Offshore Audits Have Begun The IRS has begun the first round of offshore income, asset and bank account reporting audits, and once contacted by the IRS a taxpayer cannot file OVDP or other FBAR compliance paperwork or applications. At this point the only alternative is to contact the...
Is the IRS Offshore Voluntary Disclosure Program or OVDP the Right Alternative for FBAR Compliance?
FATCA has completely changed the international financial landscape - from FBAR crackdowns to the "Panama Papers." Recently, many people have asked "Is the IRS Offshore Voluntary Disclosure Program or OVDP the right alternative for FBAR compliance or should I/we consider the streamlined application? The central question from the perspective of...
Don’t Let IRS Impeachment Hearings Fool You – The IRS Offshore and FBAR Audits Aren’t Going Anywhere but Up
Don't be distracted by the US House of Representatives hearings where they are attempting to impeach IRS Commissioner John Koskinen. The commissioner stands accused of many allegations including lying to congress, abuse of power and other acts that diminish confidence in one of the US Government's most powerful agencies. Meanwhile,...
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...
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...

