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...
New IRS Guidance to Ease Transition to the Revenue Recognition Rule
It is important to consider new IRS guidance to ease transition to the Revenue Recognition Rule. In 2014 the IRS revenue recognition standard took effect for publicly traded corporations. Almost all other businesses were required comply to the new standard in late 2018. The Financial Accounting Standards Board (FASB) released...
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...
How Will Marrying a Non-US Citizen Affect Your Taxes?
How will marrying a non-US citizen affect your taxes? What are some of the hidden issues that the IRS and California tax agencies may raise in an audit? The United States is one of the few countries who tax worldwide income. US taxpayers and expatriates must report all foreign bank...
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...
IRS Extends the Personal Tax Deadline to May 17 2021
Many US taxpayers have reacted positively to the news as the IRS extends the personal tax deadline to May 17 2021 from the usual deadline of April 15. For the second year in a row the Internal Revenue Service has give Americans an extra amount of time to submit personal...
Why a US Taxpayer Should Never Communicate with the IRS Directly
There are many reasons why a US taxpayer should never communicate with the IRS directly.? If you have received a "Letter of Notification" from the agency regarding an IRS audit or a collection action such as a Levy or Garnishment, the IRS has you in their sights.? The IRS has...