By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Thursday, November 6, 2014. Ok, so maybe I've been hiding money or assets offshore instead of keeping them here in San Diego. Yes, I have probably failed to report it on my FBARs. I hear I...
IRS Adds More Swiss Banks to Automatic 50% OVDP Penalty List
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Tuesday, June 9, 2015. The IRS has added severl new Swiss banks to the list of institutions that carry a mandatory 50% penalty instead of the 27.5% penalty provided in most OVDP filings. It doesn't matter...
Filing for OVDP Streamlined Domestic Offshore Procedures Could Reduce Your Penalty from 50% to 5% – a Large Sum for Any US Taxpayer
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Friday, July 4, 2014. The new Streamlined Domestic Offshore Procedures within OVDP represent a tremendous opportunity for any US taxpayer with foreign accounts and assets to come into compliance with the IRS, and reduce their penalties...
New OVDP Streamlined Domestic Offshore Procedures Do Not Provide Civil or Criminal Protection
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FBAR on Friday, July 18, 2014. The recent release of the OVDP Streamlined Domestic Offshore Procedures (with a deadline of August 4th) was greeted with excitement in many quarters. Who wouldn't want to reduce penalties from 27.5% down...
How Will Information Obtained by the IRS from Foreign Banks Trigger Audits for San Diego and Southern California Taxpayers?
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Sunday, September 28, 2014. The IRS recently obtained a windfall (from the IRS' perspective) of financial information relating to foreign accounts and assets specifically tied to US taxpayers or entities. Pressure brought upon foreign institutions by...
Willful or Non-Willful Conduct with the IRS and Foreign Bank Reporting
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Tuesday, August 25, 2015. The central issue relating to the Foreign Account Tax Compliance Act (FATCA) and the associated Foreign Bank and Financial Account Report (FBAR) is whether conduct on the part of the US taxpayer...
FBAR due date moved up a few months to coincide with Tax Day
On behalf of Janathan L. Allen, APC posted in Tax Controversy on Monday, August 24, 2015. As we have talked about many times on this blog, financial accounts and holdings overseas have a massive impact on your taxes -- even more so nowadays as the U.S. government pushes other countries...