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IRS Tax Lawyers in San Diego

The attorneys at Allen Barron provide the experience and expertise to handle the needs and concerns of those who are seeking IRS tax lawyers in San Diego.  We provide a comprehensive suite of services for those who are faced with IRS actions such as: IRS Audit IRS Collection Action IRS Garnishment or...

What Constitutes Willful Conduct From the Perspective of the IRS

What is it that constitutes willful conduct from the perspective of the IRS as it relates to offshore financial activities and the FBAR?  This question is at the heart of compliance for US taxpayers with offshore accounts and assets.  The difference in that legal distinction represents an exponential difference in...

Attorney-Client Privilege is the Best Protection You Have When Dealing with the IRS

Whenever you are dealing with the IRS the Attorney-Client Privilege is the best protection a US taxpayer can employ.  The Attorney-Client Privilege protects all information shared in confidence between a taxpayer and their attorney.  This extends to all paperwork, notes, personal papers, cell phone calls, emails and even texts.  The...

IRS has Released Finalized PFIC Regulations

The IRS has released finalized PFIC regulations as well as proposed new regulations which relate to the modification of PFIC rules.  A few years ago the IRS issued temporary rules regarding ownership of Passive Foreign Investment Companies (PFIC) and how shareholders in these companies would be taxed.  The IRS has finalized...

Has the IRS Stopped Collecting Taxes From High Income Earners?

Has the IRS stopped collecting taxes from high income earners?  Is past performance an indicator of future risk associated with an IRS audit? A recent Newsweek article flatly stated “The government just admitted it doesn’t really try to collect rich people’s taxes.”  A recent study by Syracuse University researchers showed...